RAP Changes Now Underway

There’s no upfront payment for home health agencies in 2021

Welcome to the new year here!

You have five days to have your RAP submitted and accepted, or your home health agency will face a hefty penalty. Adjusting to this time frame will require workflow and policy changes, even as agencies are still dealing with COVID-19 response.

Below is a brief webinar for tips you can use to create a more streamlined workflow.

“This has many agencies really worried about how this is going to work,” said J’non Griffin, President of Home Health Solutions, a Simione Coding Company. “But there’s a great deal of misunderstanding and misinformation out there, and fortunately it may not be as difficult as some agencies are worried about.” The criteria used for RAP submission is changing, too, which will simplify the process, according to Griffin. Although the first billable visit must be completed and the agency must have written or verbal physician’s orders prior to submitting the RAP, the Centers for Medicare and Medicaid Services (CMS) has done away with some other submission requirements and made a few previous requirements optional.

These changes should make a timely submission process possible for agencies which have in place effective processes to monitor RAPs and make certain penalties are not incurred, Griffin said. “The penalties will be important to avoid, as they are significant,” she said.

Griffin joined a panel of Simione Healthcare Consultants for a complimentary webinar last November to review the new RAPs requirements and provide best-practice approaches to avoid penalties and achieve quality outcomes in tandem with timely, accurate billing and coding for stronger financial results. The 60-minute webinar will provided a brief overview of the Final Rule for 2021 approved by CMS last week, summarize RAPs changes and review concerns about handling coding and OASIS, billing and selection of HIPPS codes as related to RAPs changes. Griffin will be joined by Rob Simione, Director of Financial Consulting for Simione, Kimberly Chapman, Senior Manager of Financial Consulting for Simione, and Michael Simione, Manager of Finance and Data Analytics for Simione.


  • Review of CMS requirements for RAP submissions
  • How the timing of OASIS and coding fits in
  • Strategies to work with your EMR to smooth the process
  • Ways to track all of the pieces using dashboards
  • Discussion of how LUPA periods could lead to even more penalties
  • Live Q&A