With periods beginning in 2022, CMS has replaced monthly RAPs with a one-time Notice of Admission (NOA). For agencies with patients continuing care from 2021, an NOA will need to be submitted with an artificial “admission” date beginning on the first day of the first period in 2022.
 
In a detailed Q&A, the Medicare Administrative Contractors have offered an example: If a beneficiary began care on Dec. 15, 2021, and the new period of care will begin on 1/16/2022, the NOA should use the same date as the “From” date of the new billing period, e.g., 1/16/2022.
 
Unlike a new admission, there is no requirement to perform a visit on the artificial “admission” date.
 
Here are some more questions and answers on the artificial “admission” date.
 
Question: Does the five-day NOA submission requirement apply to the artificial NOA for periods spanning 2021- 2022?
 
Answer: Yes, the five-day submission requirement applies to all NOAs, including those billed with an artificial admission date when a period of care carries over into 2022 from 2021.
 
Question: When using an artificial admit date on periods of care that continue into 2022 from 2021, will the artificial admit date be the admit date on all claims going forward rather than the real admit date?
 
Answer: Yes. Since an admission in 2022 is required for the NOA, the guidance to bill an artificial admission date that corresponds to the “From” date of the period of care in 2022 in essence changes the admit date for the periods of care going forward. For example, a new period of care beginning on 1/16/2022 requires an NOA with that date. The next period of care begins 2/15/2022 and care continues until the beneficiary is discharged on 5/2/2022. The claims would be billed as follows:
 
• Admit date 1/16/2022; “From” and “Through” dates 1/16/2022 – 2/14/2022
• Admit date 1/16/2022; “From” and “Through” dates 2/15/2022 – 3/16/2022
• Admit date 1/16/2022; “From” and “Through” dates 3/17/2022 – 4/15/2022
• Admit date 1/16/2022; “From” and “Through” dates 4/16/2022 – 5/2/2022
 
See the complete Q&A on the notice of admission at https://bit.ly/3eIH5GK.