With the implementation of the Notice of Admission (NOA) process, Medicare established a new foundation for how home health agencies (HHAs) report the start of care for patients. Designed to replace the previous Request for Anticipated Payment (RAP) system, the NOA aims to simplify administrative processes and align billing practices more closely with patient care timelines. This article provides a detailed guide to the NOA requirements, including who should submit it, when it’s required, and what details are needed for compliance.
When and How Often Must the NOA Be Submitted?
Home health agencies are required to submit a single NOA when a patient is admitted to home health care services. Unlike the old RAP process, a new NOA is not required for every 30-day period. Instead, one NOA is sufficient to cover all contiguous periods of care from admission through discharge, provided there are no interruptions or changes in agency.
Exception: For patients who began services in 2021 and continued into 2022, HHAs were required to submit a one-time NOA with an “artificial” admission date aligned with the first 2022 period of care.
Can the NOA Be Submitted Early?
No. The NOA cannot be filed until two specific conditions are met:
The home health agency has conducted an initial visit that establishes the start of care.
The agency has received either a verbal or written physician/practitioner order for services.
Submitting the NOA with a future date (in the "Admission," "From," or "Through" fields) will result in the claim being rejected and returned to the provider.
Transfers and Condition Code 47
In cases where a patient transfers from one HHA to another within a 30-day period, the receiving agency must submit the NOA using Condition Code 47. This code:
Signals a transfer of care.
Automatically closes out the patient’s previous home health episode with the former agency.
May also be used when a patient is discharged from another HHA, but the prior claim has not yet been submitted or processed.
No Other Condition Codes: NOAs should only use Condition Code 47 when necessary. Applying other condition codes will result in rejection. Notably, CC 07 (used in hospice for unrelated conditions) should not be used on an NOA.
Do NOAs Require a HIPPS Code?
When submitting the NOA electronically via the 837I format, a placeholder HIPPS code of ‘1AA11’ is required. However, HIPPS codes are not required if the NOA is submitted through other formats.
Unlike the RAP process, there is no requirement for the HIPPS code on the NOA to match that on subsequent final claims. Home health agencies should use Grouper-produced or valid HIPPS codes on period-of-care claims, not the NOA.
Is There a Requirement to Submit a Notice of Discharge?
No. A separate discharge notice (like those used in hospice) is not required in home health. Instead, a discharge is indicated by billing a final claim with a discharge status code.
Diagnosis Code Requirements
NOAs require only the principal diagnosis code and do not require secondary diagnoses. Additionally:
The principal diagnosis listed on the NOA does not have to match the one used in the final claim.
If the primary diagnosis changes after the NOA is submitted, there is no need to cancel or resubmit the NOA. The diagnosis code on the period-of-care claim will determine the PDGM grouping and reimbursement.
Submitting the NOA in DDE
When manually entering the NOA into the Direct Data Entry (DDE) system:
You may choose either the Home Health option (26) or the NOA/NOE option (49).
Regardless of the option chosen, the claim type must be set to 32A to designate an NOA.
Medicare Secondary Payer (MSP) and NOAs
Even if Medicare is not the primary payer, an NOA is still required for all Medicare beneficiaries. However:
NOAs are submitted as if Medicare is primary, and they bypass MSP edits.
All necessary MSP information should instead be included on the final claim for the period of care.
Do Other Payers Require NOAs?
The NOA requirements outlined here apply specifically to Original Medicare. For Medicare Advantage or commercial plans, agencies must contact the specific payer to determine their expectations. Some may mirror Medicare's NOA rules, but many have unique processes.
Attending Physician NPI: Individual vs. Group
The Attending Physician field on the NOA must include an individual NPI—not a group NPI. To verify this, agencies can check the National Plan and Provider Enumeration System (NPPES) or NPI Registry online.
What Defines an Admission?
The admission period begins when the patient is formally admitted to the home health agency. Events like:
A hospital transfer without discharge from the HHA,
Recertification at the end of a 60-day episode, or
Temporary transitions to inpatient facilities
do not require a new NOA unless the HHA formally discharges the patient and later re-admits them. If the patient is kept on service, no new admission (and therefore no new NOA) is necessary.
Special Case: Transition from 2021 to 2022
For patients whose home health services began in 2021 and continued into 2022, Medicare required a one-time NOA using an artificial admission date. Key notes:
The artificial admit date should match the “From” date of the 2022 billing period.
There is no requirement to conduct a visit on the artificial admission date.
The artificial admit date will carry forward on all subsequent claims through discharge.
The standard five-day submission window still applies to these NOAs.
Example:
If a patient began care on 12/15/2021, and the next billing period begins 1/16/2022, the NOA should reflect 1/16/2022 as the new admit date. That date will remain the official admission date for all claims until discharge.
Conclusion
The NOA process represents a streamlined approach to managing the start of care documentation in home health. By understanding when to submit, what codes to use, and how to handle special circumstances, home health agencies can stay compliant and avoid delays in reimbursement.
Remember: Proper NOA management is crucial for billing accuracy and care continuity. If you need support with NOA submission, compliance reviews, or system training, HealthBridge offers expert consulting to help your agency stay ahead of the curve.
