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Review Choice Demonstration: Providing You with Tools to Prepare

A Review Choice Demonstration (RCD) Toolkit is now available in the Member Portal on our website at www.ochch.org. Created by OCHCH’s Home Health Committee, the toolkit provides an overview of RCD, explains how it will be implemented, and provides examples of Face to Face documentation, regulatory articles, and audit tools. To access the new toolkit, log into the Member Portal and choose the Home Health Toolkits in the left column.

The five year claims review demonstration was scheduled to begin in Illinois on December 10, but was delayed. At this time, CMS has not announced a new implementation start date for Illinois. Ohio will be the second state to being RCD. The demonstration will be phased into Ohio with at least 60 days’ notice before implementation. With the delay in Illinois, the start date in Ohio should be pushed back to at least March 2019. Once the selection period begins, Ohio home health agencies will have until two weeks prior to start of the demonstration to select an initial review choice.

“Despite the delay, OCHCH encourages home health agencies to prepare for RCD,” stated Beth Foster, RN, BA, CHPQ, CEHCH, OCHCH Regulatory Affairs Director. Beth has been participating in quarterly conference calls on RCD with Palmetto GBA.

More About the Review Choice Demonstration (RCD):

Home home providers in the demonstration states (Illinois, Ohio, North Carolina, Florida, and Texas) have an initial choice of three options:
• Pre-Claim Review (PCR);
• Post-payment Review; or
• Minimal Post-payment Review with a 25 percent payment reduction for all home health services

During this 5-year intervention period, CMS will test the use of review options for home health services covered under Part A of the Medicare Fee-for-Service program. CMS believes this demonstration will develop improved procedures for the identification, investigation, and prosecution of potential Medicare fraud through either pre-claim or post-payment review.

RCD does not create new documentation requirements. Home Health Agencies (HHAs) will submit the same information they are currently required to maintain for payment. Medicare Beneficiary eligibility and benefits remain the same with this demonstration.
OCHCH will continue to provide you with information on RCD as it becomes available. To help providers prepare, we will offer another RCD workshop in the first quarter of 2019. Please watch The Bulletin and our social media channels for more information.