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The requirements for the Notice of Admission (NOA) will not begin until 2022. CMS has not yet announced how the NOA will be processed.
In the current proposal, a one-time notice of admission would be filed by all home health agencies beginning in 2022 to alert the claims processing system that a beneficiary is under a home health episode of care. This will replace the RAP, which is being phased out (paid at 20% for 2020) and is intended to prevent multiple agencies providing services and will establish the beneficiary’s agency of record, which is currently established by the filing of a RAP by the home health agency. Penalties will also be assessed if the NOA is filed later than 5 days after the SOC.
Note that in 2021, all agencies will still be required to submit RAPs but will receive 0% payment for these RAPs. There will be a non-timely submission reduction in payment amount tied to late RAP submission in 2021. This penalty will be assessed when the RAP is not submitted within five calendar days from the start of care or within five calendar days of day 31 of subsequent payment periods. This penalty will be a reduction equal to 1/30th of the 30-day period amount for each day from the Start of Care until the no-pay RAP is submitted.
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