The transition to the Patient-Driven Groupings Model (PDGM) in Medicare Home Health services brought significant administrative changes for agencies. This payment model shifts reimbursement focus to patient characteristics and care needs, requiring new reporting mechanisms. The Notice of Admission (NOA) is a mandatory administrative requirement under this framework. Agencies must complete this notification process before they can successfully bill for services provided to beneficiaries.
Defining the Notice of Admission
The Notice of Admission is a one-time administrative submission to the Medicare Administrative Contractor (MAC) that formally establishes a patient’s start of home health care. This filing, which uses the Type of Bill (TOB) 32A, acts as the official notification that a home health episode has begun. The NOA replaced the former Request for Anticipated Payment (RAP) under the PDGM, which Medicare phased out to eliminate up-front payments.
The primary purpose of the NOA is to “claim” the patient, establishing the agency’s liability for the 30-day payment period. This single submission covers all continuous 30-day periods of care until the patient is formally discharged. The NOA must include specific data elements, such as patient identifiers, the admission date, and the start of care date.
Before submission, two criteria must be met. The agency must have received a written or verbal order from the physician or allowed practitioner for the initial visit. Additionally, the initial visit must have been conducted, and the individual formally admitted to home health care.
The NOA Submission Process and Requirements
The process for submitting the Notice of Admission is governed by a strict timeline to ensure prompt notification to Medicare. The NOA must be submitted to and accepted by the Medicare Administrative Contractor (MAC) within five calendar days of the patient’s start of care (SOC) date. This five-day window is calculated starting the day immediately following the SOC or admission date.
If a patient is transferred between agencies within a 30-day period, the receiving agency must submit an NOA using condition code 47. This code signals the MAC that the prior admission period from the previous agency should be closed. Accepted submission methods are electronic, typically through the Direct Data Entry (DDE) system or the Electronic Data Interchange (EDI).
The date the MAC accepts the NOA determines if the timeliness requirement is met. For new admissions, the NOA cannot be submitted early; it must align with the date the physician order is received and the initial SOC visit is completed. Failure to adhere to the five-day deadline carries direct financial consequences for the home health agency.
Financial Implications of Late or Incorrect Filing
Failure to submit the Notice of Admission within the five-calendar-day window results in a financial penalty known as the non-timely submission reduction. Medicare reduces the 30-day period payment amount for each day the NOA submission is late. The penalty involves a reduction of 1/30th of the full 30-day payment amount for every day the NOA is delayed, starting from the start of care date until acceptance.
This late filing penalty reduces the reimbursement the home health agency receives for the initial 30-day period. For example, an NOA submitted ten days late results in a payment reduction equivalent to ten days of the 30-day payment amount. The penalty is considered a provider liability, meaning the agency is prohibited from billing the beneficiary for the amount of the reduction.
An extremely late NOA submission can impact subsequent 30-day periods, resulting in a penalty applied to more than one billing period. If an agency submits an erroneous NOA that must be canceled and resubmitted, the resubmission date determines timeliness, potentially triggering the daily reduction. The integrity of the NOA submission is tied to the agency’s ability to receive full reimbursement.
Subsequent Billing and Discharge Notifications
Once the Notice of Admission is accepted by the Medicare Administrative Contractor, it remains active and covers all contiguous 30-day payment periods. The NOA serves as the foundational document that allows the agency to submit final claims for reimbursement. For each 30-day period, the agency submits a final claim using the Type of Bill (TOB) 329.
This final claim references the accepted NOA to reconcile services and calculate the final reimbursement under the PDGM. Unlike the former RAP, the NOA is not a claim for payment, but a prerequisite for all final claims. It remains active until a formal discharge notification is processed.
To close the episode of care, the agency must notify Medicare of the patient’s discharge. This notification, referred to as the Notice of Termination or Discharge (NOTR), is the final required filing. If the patient is readmitted for subsequent services, the agency must submit a new NOA.