A CMS change request issued April 7, 2022, is addressing issues identified with a unique issue with the transition to the Notice of Admission from the Request for Anticipated Payment, as well as a revision to make sure gaps in care are calculated consistently.
The CR 12657 corrects the NOA process so that an NOA isn’t required for billings for denial notices (TOB 320 and condition code 21).
“This is important to for agencies to have a general awareness of, but the typical agency rarely, if ever, bills a no-pay claim,” says Aaron Little, managing director of BKD CPAs & Advisors based in Springfield, Mo. “In the event there’s a situation where a no-pay claim is needed, so long as the agency refers to the CMS guidance and they see that no NOA is needed then that should be sufficient.”
The change request also corrects a system calculation of 60-day gaps in home health services. Medicare administrative contractors recently identified a minor variance between eh way the 60-day gap is counted and used to determine if a period is early or late and to identify early periods that should pay a Low Utilization Payment Adjustment (LUPA) add-on amount, according to CMS.