CMS Pub. 100-08, ch. 4, § 4.4.1

In monitoring the use of NOAs and Home Health claims, a MAC may identify potential

misuse that is not significant enough to warrant immediate implementation of a

Corrective Action Plan, but may indicate the need for additional education and

monitoring. The MAC shall educate the HHA on the appropriate use of NOAs.

Appropriate steps include calling the HHA to discuss the concerns identified,

distributing educational materials to the HHA, and/or sending correspondence to the

HHA. At a minimum, the MAC shall make clear to the HHA that:

• the HHA’s billing practices are inconsistent with Medicare policy guidelines;

• the HHA’s billing practices are being subjected to increased monitoring;

• if improvement is not demonstrated upon completion of a reasonable

monitoring period (e.g., 30 days), there is potential for additional future

action, including Corrective Action Plans and/or referral to the UPIC; and

• the MAC will convey next steps, if any, upon completion of the monitoring

period.

Once the monitoring period has ended, the MAC shall inform the HHA of the outcome.

This may include no additional action being taken, the monitoring period being extended

or the implementation of additional corrective action, including but not limited to a

Corrective Action Plan as detailed in Section 4.4.3.