2022 Notice of Admission (NOA)

What is 2022 Notice of Admission (NOA)? 

Just when agencies figured out how to handle 2021 No Pay RAP, CMS announced a change away from No Pay RAP to Notice of Admission.  In our view, this is a positive change and reduces headaches for agencies.  There are some key differences from 2021 No Pay RAP, but many similarities. 

On May 11, CMS released a memo saying that No Pay RAP will be replaced on January 1, 2022 with a Notice of Admission process.  You can read the memo here (2022 NOA Memo).  The memo explains how to do submit an NOA, but there are some key differences that need to be explained.  

The 2022 NOA is what the 2021 No Pay RAP should have been in the first place.  Essentially, the NOA is the way by which agencies tell CMS that a patient is on service.  In previous posts, we explained the 2021 No Pay RAP.  You can read that (here).  

We will describe what is the same, what changes, and some special considerations that agencies need to be aware of to be successful.  

Similarities between 2022 NOA vs No Pay RAP

The framework of NOA and No Pay RAP is very similar.  Agencies still have 5 days to submit a NOA and have it accepted by the Medicare Administrative Contractors (MAC).  It is essential to note that the NOA (or RAP) must be ACCEPTED by the MAC by day 5.  Don't leave it to chance to get the NOA submitted and accepted by the MAC.  

Here is what is required to submit the NOA:  "To submit an NOA, you must have a verbal or written order from the physician that contains the services required for the initial visit. You must have conducted an initial visit at the start of care."  That's it!

Agencies will still be required to submit NOAs within 5 days from the Start of Care.  

Penalties will still apply, but it appears that penalties have the potential to be harsher.  We will detail those below.  

How is 2022 NOA different from 2021 No Pay RAP? 

Here are the key differences (as of this writing and will be updated as more information comes out): 

• The requirement for a valid diagnosis code and HIPSS code has been eliminated.  Only order for services and first visit complete is required to submit NOA.  
• "CMS only requires 1 NOA for any series of HH POCs beginning with admission to home care and ending with discharge. Once you report a discharge to Medicare, you must send a new NOA before you submit any additional claims."  That's right, no more 2 RAPs for each 30 day episode!  Billers should be excited about this!
• Penalties are not capped at 30 days.  If an NOA is not filed until day 45, then the penalty will be 45 days.  File the NOA on time!

Key Considerations for 2022 RAP

If a patient begins service prior to 2022 but carry over after January 1, 2022, "For all patients receiving HH services in 2021 whose services will continue in 2022, you should submit an NOA with a one-time, artificial “admission” date corresponding to the “From” date of the first period of continuing care in 2022."  That means agencies need to submit a NOA for all patients on the first from date in 2022.

"Medicare won’t make Low-Utilization Payment Adjustment (LUPA) per-visit payments for visits that occurred on days that fall within the period of care prior to an NOA submission."  Stay out of LUPA and get the NOA in on time!  

2022 NOA Exceptions

There are 4 Exceptions that CMS may grant if you are late filing a NOA. 

• Fires, floods, earthquakes, or other unusual events that inflict extensive damage to the HHA’s ability to operate
• An event that produces a data filing problem due to a CMS or MAC systems issue that is beyond your control
• You are a newly Medicare-certified HHA that is notified of that certification after the Medicare certification date, or which is awaiting its user ID from its MAC
• Other circumstances that we or your MAC determines to be beyond your control

Here is when CMS will not grant exceptions:

• You can correct the NOA without waiting for Medicare systems actions
      • You submit a partial NOA to fulfill the timely-filing requirement
      • You have multiple provider identifiers and submit the identifier of a location that didn’t actually provide the service

Here is a link to  CMS Chapter 10 Claims Processing Manual

A proactive approach by agencies will help agencies be successful going into 2022.