May 5, 2021
Documenting Your Home Health Exception Request for Late RAPs
As of January 2021, a payment reduction applies to a home health final claim when the request for anticipated payment (RAP) is not submitted timely. Home health providers may request an exception to the late RAP penalty by reporting KX modifier on the final claim with the Health Insurance Prospective Payment System (HIPPS) code on the revenue code 0023 line. In addition, you must include information in the “REMARKS” field indicating the reason the RAP was submitted untimely.
Documentation Submitted With an Exception Request
The “REMARKS” information must document how one of the four circumstances, listed below, qualify for an exception. If the information provided is not clear or if the “REMARKS” field is blank, CGS will issue a non-medical review additional development request (Non-MR ADR) with reason code 7RMRK.
- Fires, floods, earthquakes, or other unusual events that inflict extensive damage to the HHA’s ability to operate
- An event that produces a data filing problem due to a CMS or MAC systems issue that is beyond the control of the HHA
- A newly Medicare-certified HHA that is notified of that certification after the Medicare certification date, or which is awaiting its user ID from its MAC
- Other circumstances determined by the MAC or CMS to be beyond the control of the HHA
When submitting documentation in response to the Non-MR ADR, do not submit medical documentation. Submit clear information that demonstrates one of the four circumstances. For example, if the RAP was late due to a claims processing issue, document which issue caused the delay. If you are newly certified HHA, submit documentation showing when you became a Medicare certified provider. If it’s because of overlapping periods of care, show that efforts made to resolve the overlap.
Refer to the Examples of Denied/Granted RAP Exception Requests for assistance when requesting an exception.
Additional Resources: