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April 19, 2022

Untimely NOA Exception Requests Received in Error

As a reminder, a Home Health Notice of Admission (HH NOA) must be submitted within five calendar days after the admission date. If an NOA is not filed timely, you may request an exception, which, if approved, waives the consequences of late filing. The four circumstances that may qualify for an exception are:

  • Fires, floods, earthquakes or other unusual events that inflict extensive damage to the home health agency’s (HHA’s) ability to operate
  • An event that produces a data filing problem due to a CMS or MAC system issue that is beyond the HHA’s control
  • A newly Medicare-certified HHA that is notified of their certification after the Medicare certification date or is awaiting its user ID from the MAC
  • Other circumstances determined by the MAC or CMS to be beyond the HHA’s control

Since the implementation of the HH NOA on January 1, 2022, several system-related processing issues were identified. As a result, in certain instances (e.g., reason code 32114), we indicated that you may request an exception for an untimely NOA submission (i.e., add modifier KX to the HIPPS code reported on the revenue code 0023 line and certain Remarks on the final claim) to expedite processing.

However, we recently identified a high volume of claims submitted with modifier KX in error. For example: The Claims Processing Issues Log indicates reason code 32114 was resolved on January 14, 2022, but we continue to receive TOB 329 claims with modifier KX.

When modifier KX is reported, we must suspend the claim to validate information was submitted for an untimely NOA. Therefore, when modifier KX is reported on a claim when the NOA is not late and/or a processing issue is resolved, this results in unnecessary delays in processing your claims.

Please continue to monitor the Claims Processing Issues Log and only report modifier KX when appropriate.

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