CMS is alerting providers of a third RAP system error this month. This one could erroneously lead to payment penalties for agencies that submitted two RAPs simultaneously for two 30-day payment periods.  
 
The latest issue was announced Tuesday during a CMS Open Door Forum with home health and hospice providers.
 
Under the new RAP rules, effective Jan. 1, a slimmed-down RAP must be accepted by the Medicare Administrative Contractors (MACs) within five days of the start-of-care date, or the agency will receive a penalty equal to 1/30th of the total payment for each day past the start-of-care date.
 
CMS says the system will erroneously trigger a similar penalty for RAPs that are submitted early. This is a problem because CMS stressed to providers in the months leading up to the RAP changes that they can and should submit the first two 30-day periods simultaneously as a way to avoid processing issues.
 
Due to the system error, those providers who have already submitted RAPs for the second 30-day period will risk temporary payment penalties by submitting claims ahead of March 1, the date when CMS expects the issue will be corrected.
 
According to CMS, you have two options for those February claims:
  • You can avoid erroneous penalties by holding off submitting claims until on or after March 1 for any February periods of care for which you submitted the RAP in advance.
  • You can submit those claims normally and receive the payment penalty. During the weeks following March 1, MACs will automatically adjust and correct any claims that received the penalty in error, according to CMS. The MACs will send the corrected payment without any action needed by the agencies.
“It’s a huge hiccup, but I would move forward and continue sending both RAPs at the start,” says Annette Lee, owner of Provider Insights Inc. in Des Moines, Iowa. But, for end-of-episode claims where the second RAP was submitted early, wait until the system is fixed March 1.
 
2 other RAP errors
 
The latest issue follows two other RAP system errors identified earlier this month.
 
On Jan. 20, the MACs alerted providers to of an error causing RAPs to be incorrectly returned with reason code W7216 indicating an invalid line item date. Palmetto GBA and CGS noted in recent alerts that the issue is being researched by technical support and no provider action was required.
 
That issue came on the heels of another error related to RAP submissions returned in error. In early January, Medicare systems were returning RAPs for missing value code 61, according to CMS. The field for you to report a Core-Based Statistical Area (CBSA) code is now optional.
 
As a workaround, MACs will add value code 61 and placeholder CBSA code 10180 to these RAPs so they continue processing. Agencies don’t have to take any action and may disregard the added codes.
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