With a February update to the Review Choice Demonstration (RCD) frequently asked questions, CMS addresses questions about claims not subject to RCD and notes that number of visits does not matter when it comes to RCD.
 
From the updated FAQ:
 
Are any claims exempt from the RCD process?
 
Home health claims for Veteran Affairs, Indian Health Services, Part A/B rebilling, demand bills submitted with condition code 20, no-pay bills submitted with condition code 21, and Request for Anticipated Payment (RAP)/Notice of Admission (NOA) are not subject to the demonstration. Claims for beneficiaries in another Medicare demonstration, such as an Accountable Care Organization (ACO), are also not subject to the demonstration.
 
What if a beneficiary only requires a few home health visits? Will the claim still be subject to the demonstration?
 
Initially claims with 4 or fewer visits were excluded, but as of April 1,2020, all billing periods are subjected to the RCD regardless of the number of visits.