Medicare Has Been Fixing This Home Health Edit Since 2023
CMS issued a change request Thursday that stops home health claims from being returned when the Notice of Admission has aged out of the system. The same three-line substitution was written in August 2021 and rewritten in July 2024, and this version does not touch a claim until April 5, 2027. Until then the fix is a person at your MAC building a replacement NOA every week, and the date that NOA carries is the date the Pricer prices against.
Medicare keeps the date your Notice of Admission arrived in a file called HRAP. Request for Anticipated Payment: the document NOAs abolished on January 1, 2022, still lending its name to the table that decides whether a 30-day period pays in full.
CMS purges that file. The admission it describes does not stop.
On Thursday CMS issued Transmittal 13996, Change Request 14605, under a subject line that reads like a bug ticket because that is what it is: "Home Health Reason Code 19963 Edit, Notice of Admission Not Found." One business requirement, one page of substance, effective April 1 and implemented April 5, 2027.
Read the requirement and you have seen it before. So had CMS.
"What does a claim do when the only surviving record of its admission has been deleted?"
The Sentence CMS Has Now Written Three Times
Only one NOA exists for an entire home health admission. Chapter 10 is explicit: one NOA covers "any series of HH periods of care beginning with admission to home care and ending with discharge."
File it once, recertify forever, and a patient on service for three years generates thirty-odd claims against a single NOA receipt date sitting in HRAP.
HRAP gets purged at 24 months. The claims do not.
CMS anticipated this the first time around. Transmittal 10977 of August 19, 2021, the one that retired RAPs, carried requirement 12227.2.4.2: where no NOA can be found and the claim From date is 24 months or more after the admission date, send the admission date to the Pricer in the receipt date field instead. The attached note is almost wistful. "The NOA is assumed to have been received in the past and subsequently purged from the file where the NOA receipt dates are stored."
That covered claims whose service dates had themselves aged past two years. It did not cover a claim whose From date was inside 24 months and whose Through date fell outside, so CR 13684 went out on July 18, 2024 and added that case, implementing January 6, 2025.
Thursday's CR adds the third corner of the same box: From and Through both inside 24 months, claim received after. Three requirements, one field, and the arithmetic on the gap is unkind (chart below).
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