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Texas RCD: Remember to Choose!

From the desk of

Joe Osentoski, BAS, RN-BC

ADR and Appeals Specialist

Gateway Home Health Coding & Consulting LLC

Medicare Administrative Contractor Jurisdiction M Palmetto GBA updated their state of Review Choice Demonstration (RCD) selections made by Texas home health agencies on February 4, 2020.

The results so far are:

Pre-Claim Review (PCR) 93%

Post-Payment Review 6%

Minimal Review 1%

Note that these reflect the percentage of agencies in category that have gone on Palmetto GBA’s eServices and made a choice. It does NOT show the results for all agencies in Texas. And this shows a potential problem.

Within the Initial RCD Choices available, selecting 100% pre-claim review (Choice 1) is the best selection for the vast majority of agencies. Opting for a 100% post-payment review (Choice 2) equates to putting the home health agency on a self-inflicted 100% Additional Development Request (ADR) review, and can have serious cash flow implications as ADRs are processed. Finally, unless the agency has a very small number of Medicare patients, taking a 25% payment reduction on all home health claims in exchange for no review (Choice 3) seems a non-starter.

Even more concerning, though, is the apparently high number of Texas agencies that have not yet made any choice. If they do not make a selection by February 13, 2020, they will be put into the default Choice 2 100% post-payment review for the initial six-month RCD cycle. Nearly one-third of agencies in Ohio fell into this category when RCD started in that state, and Texas seems to be following suit.

Unless the home health agency is ready to send the entire content of the chart, for 30-day Patient Driven Groupings Model (PDGM) payment periods, on a 30-day turnaround to obtain their result, running the risk of claim denial and subsequent potentially long and costly appeals process, for 100% of their Medicare claims, these agencies need to strongly consider getting to Palmetto GBA’s eServices and get put onto Choice 1.

Remember from CMS’ last update on RCD

Update 01/16/2020:

The choice selection period for Home Health Agencies (HHAs) located in Texas began on January 15, 2020 and will end on February 13, 2020. HHAs should visit the Palmetto GBA provider portal here for information and instructions on the selection process. Through the portal, HHAs will be able to view their available choices and make their selection. HHAs that do not make a choice selection by February 13, 2020 will be automatically placed in Choice 2: Postpayment Review. Following the close of the choice selection period, the demonstration will begin in Texas on March 2, 2020, and all episodes of care starting on or after this date will be subject to the requirements of the choice selected.

Following the start of the demonstration in Texas, the demonstration is expected to begin in North Carolina and Florida on May 4, 2020. In addition, CMS will phase-in the inclusion of Low Utilization Payment Adjustments (LUPAs) within the demonstration. CMS will continue to monitor the transition to the Patient-Driven Groupings Model (PDGM) and will post updated information on this website. Please send any questions to:

Thus, much like the countdown to decision at The Alamo, time is running out for Texas home health agencies to make a choice in RCD that will best fit the agency needs and limit the amount of additional burden that RCD will place on cash flow while PDGM sorts itself out. For the vast majority of agencies, that choice is pre-claim review (Choice 1).

However, should an agency elect 100% post-payment review (Choice 2) or find themselves in the middle of appeals processing to overturn non-affirmed claims, Gateway and its' experienced appeals team can assist. Call or email us today (248) 230-9588 or

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