System errors with the new Notice of Admission (NOA) got all the attention in January, but Palmetto GBA is alerting providers to several user errors it’s seeing on submitted NOAs and related claims, particularly around late NOAs and exception requests.
 
“Home health agencies are to ensure they accurately submit late RAP or NOA exceptions,” the MAC wrote in its alert Feb. 16, 2022.
The mistakes noted include: 
  • Agency requests for late NOA or RAP exceptions when the NOA or RAP was received timely. This is done by applying the KX modifier and/or remarks unnecessarily on claims. This will cause the claim to suspend, delay its processing and the claim may be returned for correction.
  • Agency requests for late RAP exceptions on issues that affected NOAs only, or vice versa. For example, in early 2022 NOAs edited in error for Reason Code 19960, Condition Code other than 47. HHAs are submitting this issue as the reason a RAP was late, for home health claims with a "from" prior to January 1, 2022. This processing issue affected NOAs only and is not valid for late RAPs. If this exception is requested on a RAP, the exception will be denied. 
  • When there is a Medicare system issue that caused a NOA or RAP to be late, Palmetto GBA provides (when available) exact remarks on the Claims Payment Issues Log the HHAs are to submit on the corresponding claims. If the provided remarks are available and not used, it may cause delays in processing the exception or a denied exception request and lost reimbursement. 
Palmetto notes that another mistake the MAC is seeing is exception requests for claims beyond those periods where it applies.
 
If the NOA was approved five days late (so 10 days beyond the admission date), that exception request would only apply to that first period of care. If the NOA is 45 days past the admission date, then a late exception would be required for the first two claims.