Important Information Regarding Exception Requests for Late Home Health Notice of Admissions, Requests for Anticipated Payment

Palmetto GBA has seen an increase of invalid late Home Health Notice of Admissions (NOAs) and Requests for Anticipated Payment (RAPs) exception requests. Home health agencies (HHAs) are to ensure they accurately submit late RAP or NOA exceptions. Please share the below information with your billing staff.  

• HHAs are requesting 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.
• HHAs are requesting 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. 
• A late RAP only affect the one corresponding claim for that 30-day period or care. If the sequential period of care’s RAP is timely, regardless of 60-day episode timing, no late exception is required.  
• Late NOAs may affect multiple period or care claims depending on how late the NOA is received. An NOA received 10 days from the admission date, would only require an exception request, if applicable, on the first 30-day period claim. If the an NOA was received 45 days late and there are two or more periods of care in the home health admission, a late exception request is required for the first 2 period of care claims.