July 15, 2020

Partnership: Implementation of RCD Amidst Public Health Emergency Ill-Advised

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WASHINGTON – The Partnership for Quality Home Healthcare – a coalition of home health providers dedicated to improving the integrity, quality, and efficiency of home healthcare for our nation’s seniors – has expressed concern that a recent announcement from the Centers for Medicare & Medicaid Services’ (CMS) to proceed with implementation of the Review Choice Demonstration for home health services in Florida and North Carolina will inflict greater stress and administrative burden on providers already overwhelmed by the challenges of providing patient care during the COVID-19 public health emergency.

“Proceeding with the Review Choice Demonstration in two states seeing some of the highest COVID-19 surge rates in the nation is ill-advised and could result in negative, unintended consequences impacting patient care. This is the last thing providers should be asked to manage at a time when many agencies are still struggling to navigate pandemic challenges,” said Joanne Cunningham, Executive Director of the Partnership. “We strongly urge CMS to institute an immediate pause on this policy announcement.”

Under the Review Choice Demonstration, CMS will review home health agency documentation for evidence that beneficiaries meet requirements of the Medicare’s home health coverage criteria by requiring providers to choose either a pre-claim review or post-payment review of their claims. Home health providers have expressed concerns over the program since it was originally announced in 2018, including the intense administrative burden it will place on home health providers focused primarily on direct patient care.

“While combatting improper billing is always a priority, our frontline caregiving teams deserve a reprieve from additional mandates during this escalating public health crisis,” concluded Cunningham.