Simione™ Healthcare Consultants


Adopt RAP Changes for 2021 & Avoid Late Penalties

Home health agencies struggling with cash flow shortages after Medicare reduced its upfront payment to 20 percent this year could see increased financial problems in 2021, when the upfront payment is eliminated.

The greatest potential for financial duress is likely to come from stiff new penalties which will be imposed for failing to submit the paperwork associated with those disappearing payments within a new 5-day window, according to Robert V. Simione, CPA, Director, Finance Consulting, Simione Healthcare Consultants.

Beginning Jan. 1, the Centers for Medicare and Medicaid Services (CMS) will require agencies to file a non-paying Request for Anticipated Payment (RAP) within five days of the start of care for each 30-day billing period, or pay a penalty for each day the RAP is late.

“Those daily penalties will add up quickly,” Simione said.  “And no one can afford to lose a third of the payment for a 30-day period when a RAP is eight days late.”

Simione weighed in last week on some of the steps home health agencies should take in preparation for 2021’s RAPs changes. His remarks were part of a complimentary educational webinar that also featured Simione consultants Kim Chapman, Senior Manager, Revenue Cycle Consulting, Michael Simione, MBA, Manager, Finance and Data Analytics, and J’non Griffin, President of Home Health Solutions, a Simione Coding Company.

Their collective message: Successfully navigating RAPs in 2021 will require a new mindset for home health agencies, with faster turnaround times, prioritized oversight for timeliness, efficient EMR processes and smart decisions about where not to cut corners to save time.

“We can’t lose sight of what’s really important,” Griffin said. “While agencies will be required to move faster, the clinical piece of it really shouldn’t be rushed.”

OASIS and the referral

A thorough referral remains necessary to collect important information to help clinicians understand what is going on with the patient, Simione consultants said. They advised against cutting short the process.

“Together with the comprehensive assessment, the referral establishes the foundation for all agency care,” Griffin said.

New requirements do not require the OASIS to be completed before RAP submission, so agencies should continue to take advantage of the full 5-day period allowed to collaborate and conduct the assessment, she said.

“OASIS guidance has not changed,” Griffin said. “Agencies still have 5 days for a collaborative assessment, and in 2021 the RAP can be submitted before the OASIS is completed.” 

There are reimbursement considerations for agencies in as well, Griffin added. “An agency may also miss a lot of opportunities under PDGM by rushing the process.”

Getting faster elsewhere

Simione consultants said agencies will need to speed their processes in other areas, including the completion of all documentation for the first billable visit. The RAP cannot be submitted until the visit has been completed.

“Agencies may want to require clinicians to close out that visit in 24 hours, and hold their contract staff accountable as well,” Simione said. “That may have to include a financial penalty if contract staff fails to meet the agency’s 24-hour requirement.”

Watch the calendar

Holidays and three-day weekends in particular have the potential to place agencies at risk for financial loss under the new 5-day submission timeframe, Simione consultants warned.

“CMS doesn’t care about the weekend,” Griffin said. “Agencies need to have a process in place that takes into consideration those three-day weekends when there is a holiday on Monday.”

Want more information about RAPs?

Simione’s experts and outsourced services for billing, coding and OASIS review, and QAPI solutions can assist home health agencies improve revenue cycle operations in tandem with quality outcomes. To view the webinar recording, RAP Sheet for 2021 and outsourced services, visit