“Review Choice Demonstration (RCD) is a Medicare program by the Centers for Medicare & Medicaid Services (CMS), requiring selected home health agencies to choose between pre-claim review or post payment review of Medicare home health claims. Through RCD, providers prove compliance and reduce improper payments under CMS oversight.”
Are you a home health leader feeling the pressure of the Review Choice Demonstration (RCD)? Are you grappling with questions like:
- How can my agency stay compliant without drowning in paperwork?
- What does RCD mean for my patients’ access to timely care?
- Is this just another regulatory hurdle, or is there a silver lining?
You’re not alone. The RCD program, introduced by the Centers for Medicare & Medicaid Services (CMS), has sparked concern and curiosity across the home healthcare industry. Designed to reduce improper payments and ensure Medicare compliance, RCD automation is reshaping how home health agencies operate. But with change comes opportunity.
This blog explains review choice demonstration implications for home healthcare leaders like you, explores its challenges and benefits, and provides actionable strategies for surviving and thriving under this new framework. Let’s dive in!
What Is Review Choice Demonstration (RCD) in Home Health?
Before diving deeper into automation, it’s important to understand what the Review Choice Demonstration (RCD) actually means for home health agencies and why it exists. Many agencies view it as an administrative burden but in reality, RCD is CMS initiative to reduce fraud, waste, and abuse and ensure compliance, and safeguard Medicare funds in home health services.
Think of it as a “quality check” for home health services. While the program’s intent is noble—ensuring patients receive necessary, high-quality care—it has added a layer of complexity for agencies already juggling tight margins and staffing challenges.
Why CMS Introduced the RCD
CMS launched the Review Choice Demonstration program to address a long-standing challenge. The goal was to-
- Reduce improper payments by ensuring compliance with Medicare’s billing rules.
- Promote accountability in home health service delivery.
- Enhance patient protection through a rigorous home care review process.
- Minimize appeals and administrative burden.
Which States Are Included
The RCD program initially began in Illinois and later expanded to Ohio, Texas, North Carolina, and Florida. These states were selected based on claims volume and prior error rates to test the efficiency of pre-claim and post-payment review methods.
RCD Extension Update (2024)
In its latest update, CMS announced that the Home Health Review Choice Demonstration has been extended for an additional 5 years, effective June 1, 2024. This extension reinforces CMS’s long-term commitment to compliance and care quality in the home health sector.
Quick Insight:
The five-year RCD extension means that agencies in participating states should consider adopting AI and automation solutions now to stay compliant and efficient as CMS continues to expand data-driven oversight.
As the program evolves, understanding how it works — from claim submission to review — becomes essential. Let’s take a closer look at the RCD process and its implications for home health agencies.
How Review Choice Demonstration Process Works?
The RCD process ensures compliance, reduces improper payments, and rewards agencies with high compliance rates by offering fewer reviews over time.
RCD Process: Step-by-Step Overview
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Choice Selection:
In your state’s selection period, the provider chooses Pre-Claim or Post payment review (PCR).
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Submission / Documentation:
For Pre-Claim, submit required clinical documentation ahead of billing. For Post payment, submit documentation when ADR (Additional Documentation Request) is received.
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Review & Decision:
CMS (via Palmetto GBA) issues a decision (affirmation or non-affirmation). For pre-claim, this yields a Unique Tracking Number (UTN).
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Claim Processing / Reimbursement:
If affirmed (or UTN attached), the claim proceeds without further review; if non-affirmed or postpayment ADR fails, potential denial / recoupment.
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Six-Month Cycle & Compliance Rate:
Every 6 months, the provider’s affirmation / approval rate is measured. If ≥ 90% (with minimum 10 submissions), the provider may advance into selective/spot-check review.
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Subsequent Review Choice:
Providers meeting thresholds can select among Pre-Claim, Selective Postpayment Review, or Spot Check Review.
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Appeals / Audit Risk:
Denied claims may go through appeals. Even affirmed claims may be subject to CERT or random audit outside RCD.
Once home health agencies understand the RCD process, they can leverage automation to streamline each step, reduce errors, and improve compliance. The diagram below illustrates a step-by-step approach to implementing RCD automation.
Comparison of RCD Review Choices
| Review Option | When It Happens | Key Benefit | Potential Risk |
|---|---|---|---|
| Pre-Claim Review (PCR) | Before claim billing | Prevents denials by validating compliance early | Slight delay if non-affirmed |
| Post-Payment Review | After payment is made | Easier upfront processing | Risk of denials or recoupment |
| Selective / Spot-Check Review | After achieving ≥ 90% approval | Fewer claims reviewed; reduced workload | Must maintain compliance to retain eligibility |
The Review Choice Demonstration program offers home health agencies flexibility by allowing them to choose how their claims will be reviewed. The options include:
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Pre-Claim Review for Home Health (PCR)
Agencies submit documentation before billing to confirm compliance with Medicare guidelines. This proactive approach allows agencies to address issues before the claim is processed, ensuring smooth reimbursement.
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Post-Payment Review
Claims are reviewed after payment has been made. However, agencies that choose this option face a 25% payment reduction, which is only recoverable if they demonstrate a high compliance rate.
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Opt-Out Option
Agencies can choose to forgo pre-claim and post-payment reviews but will be subject to a 100% review of all claims, increasing administrative complexity and risk.
While the RCD process offers flexibility and ensures quality control, it also introduces new operational hurdles for home health agencies. From managing complex documentation to meeting tight compliance deadlines, let’s explore the major challenges agencies face under this program.
What Challenges Do Home Health Agencies Face in RCD Process?
Here are some common pain points that home health agencies deal with are-
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Varied Review Choices:
RCD automation offers providers multiple options, including pre-claim review, post-payment review, or a combination. However, this flexibility can complicate provider comparisons, as the review processes lack standardisation.
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Complexity in Data Collection:
Tracking data accurately across different review modalities—such as review requests, claim denials, appeals, and provider responses—poses significant challenges. This complexity can lead to inconsistencies or inaccuracies in reporting.
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Influence of External Factors:
Analysing the impact of home care review process becomes more complicated when external variables, such as shifts in patient demographics, changes in coding practices, or new regulatory updates, are considered. These variables can obscure clear conclusions.
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Risk of Bias:
Providers may alter their practices in response to RCD, potentially skewing the data. Careful monitoring and analysis are required to ensure an unbiased interpretation of trends.
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Delayed Data Accessibility:
Access to complete data sets may be delayed depending on the chosen review process. This lack of timely information can hinder practical analysis and decision-making.
How Can AI and Automation Simplify RCD Process?
The Review Choice Demonstration (RCD) process is critical for home health agencies to ensure compliance with Medicare requirements while minimising claim denials and delays. However, it is also resource-intensive, involving multiple stages of documentation, validation, and status monitoring.
By leveraging AI and automation solutions for home health RCD automation, agencies can streamline these steps, reduce errors, and save time and money. Here’s a detailed breakdown of how AI and automation can transform the RCD process and practical examples.
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Streamlining RCD Submission in EHR
The first step in the home care review process is preparing documentation for submission, including completing the RCD sheet and ensuring all required forms are in order. AI-powered healthcare compliance solutions automate data entry, extracting patient details from the EHR systems, and populating the submission sheet.
AI bots also perform real-time validation checks, ensuring key documents like CMS-485 forms are complete and alerting staff to missing or incomplete information for correction before submission.
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Automating Document Uploads to Palmetto GBA
After preparing Pre-Claim review for home health submission sheet, the next task is uploading it and other required documents to the Palmetto GBA portal. This step is often time-consuming and prone to manual errors. However, automated home healthcare systems streamline this process by enabling seamless integration with the Palmetto GBA system.
Automation tools can log into the portal, navigate the necessary sections, and upload documents directly from the EHR. In addition, these tools ensure that the details in the Palmetto GBA portal align with the EHR records, preventing discrepancies.
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Monitoring Review Status in Palmetto GBA
After submitting documents, agencies must track review outcomes, interpret results, and update the EHR. AI bot can streamline this by monitoring the Palmetto GBA portal in real-time and automatically processing outcomes like Provisionally Affirmative or Non-Affirmative.
Bots retrieve decisions, update the EHR with the UTN and relevant details, and notify teams of the following steps: processing approved claims or flagging corrections for denied ones.
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Reducing Operational Costs and Time
RCD automation significantly reduce the manual workload in home care review process, allowing agencies to process more claims quickly and accurately while ensuring compliance.
Tasks like document verification and system updates that once took hours are completed in minutes, boosting efficiency and lowering costs. Automation minimises errors, avoids claim denials, and frees staff for higher-value activities like patient care.
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Ensuring Compliance and Reducing Risk
Compliance with Medicare’s stringent guidelines is essential in the healthcare compliance solutions (RCD process), and AI ensures agencies meet these standards efficiently.
AI-driven Pre-Claim review for home health systems validate submissions against Medicare’s rules, maintain detailed logs for audits, and scale to handle high claim volumes. By automating these processes, agencies reduce non-compliance risk and improve operational performance.
Benefits of RCD Automation for Home Health Agencies
While the Review Choice Demonstration adds new layers of compliance and documentation, automation can transform it from a complex mandate into a strategic advantage. By integrating AI and RPA into the RCD process, home health agencies can gain multiple operational and financial benefits.
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Faster Claim Approvals
Automation accelerates pre-claim validation, documentation checks, and submissions to the Palmetto GBA portal. This means faster approvals, reduced claim rejections, and quicker payments—helping agencies maintain cash flow without delays.
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Reduced Manual Workload
AI bots handle repetitive, rule-based tasks like form filling, uploading documents, and tracking review statuses. This eliminates hours of manual labor and allows clinical and administrative teams to focus more on patient care rather than paperwork.
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Improved Accuracy and Compliance
Automation ensures that every submission follows CMS documentation standards. Intelligent bots perform real-time validation of forms like CMS-485 and flag missing information instantly—reducing the risk of denials or compliance penalties.
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Lower Administrative Costs
RCD automation helps agencies cut operational costs by minimizing manual intervention and rework. Over time, this leads to significant savings in administrative overheads and improved profitability for home health providers.
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Better Audit Readiness
All submission logs, status updates, and document versions are automatically recorded, ensuring transparent audit trails. When CMS requests verification, agencies can instantly provide complete, compliant documentation sets.
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Enhanced Staff Efficiency and Morale
With automation taking over repetitive compliance tasks, staff members experience reduced stress and better work satisfaction. Teams can redirect their efforts toward high-value, patient-centric activities that improve service quality and engagement.
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Strengthened Patient Experience
By reducing administrative delays and errors, automation ensures that patients receive timely care approvals and uninterrupted services—enhancing overall patient satisfaction and trust.
Pro Tip: Agencies that automate their RCD processes early will find it easier to adapt to future CMS updates and emerging home health compliance frameworks.
Future Trends in Review Choice Demonstration Automation
As healthcare regulations and technology evolve, the future of the Review Choice Demonstration (RCD) will be shaped by digital transformation, AI-driven decision-making, and tighter compliance integration. CMS’s recent five-year extension of the RCD program signals that automation and data intelligence will play a much larger role in the coming years.
Here are a few emerging trends shaping the future of RCD automation for home health agencies:
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Predictive Compliance and Risk Analytics
Future RCD systems will not just verify documentation — they’ll predict compliance risks before submission. AI will analyze past claim patterns, highlight potential denial triggers, and recommend corrections to help agencies achieve near-zero error rates.
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Integration of RPA with EHR and CMS Portals
The next wave of automation will bring end-to-end interoperability, connecting RPA bots directly with Electronic Health Records (EHR) and Palmetto GBA portals. This integration will create a unified, automated workflow from patient admission to claim approval.
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Use of Generative AI for Documentation and Review
Generative AI tools are expected to help clinicians and administrative teams auto-draft, summarize, and cross-check clinical notes against CMS compliance criteria — drastically reducing human effort and improving accuracy in RCD submissions.
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Real-Time Compliance Dashboards
Automation platforms will soon include real-time compliance dashboards, giving agencies a clear view of submission statuses, documentation gaps, and approval timelines — helping decision-makers stay audit-ready at all times.
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Expansion of RCD Automation Across More States
As CMS evaluates the success of the demonstration, the program may expand to additional states. Agencies that already implement automation solutions will be well-positioned to adapt quickly when new territories are added.
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Cloud-Based and Scalable Automation Models
Future-ready home health organizations will increasingly adopt cloud-native automation tools that scale easily as compliance needs grow. These platforms will ensure continuous updates in line with CMS rule changes without extra technical overhead.
Insight: The future of RCD automation isn’t just about compliance — it’s about creating a digitally intelligent home health ecosystem where every claim, document, and workflow is optimized for speed, accuracy, and patient care quality.
Conclusion: Turning Compliance into a Competitive Advantage
Navigating the Review Choice Demonstration (RCD) process can be complex, but it doesn’t have to be a barrier to efficiency or growth. By leveraging RCD automation and healthcare compliance solutions, home health agencies can transform compliance from a cumbersome regulatory burden into a streamlined, strategic advantage.
As CMS continues to evolve healthcare regulations, agencies that proactively integrate technology into their operations will stay ahead of compliance requirements while improving financial stability. The key to home health review choice process success isn’t just following the rules—it’s optimising them for efficiency and excellence.
As the RCD process grows more complex, AI and automation are no longer optional—they’re essential to staying compliant and efficient. By leveraging tools like AutomationEdge’s CareFlo AI, home health agencies can:
- Streamline documentation and submission workflows
- Reduce manual errors and denials
- Ensure CMS compliance with real-time monitoring
- Save administrative time and operational costs
Agencies that embrace AI-driven RCD automation today will be the ones leading tomorrow — equipped to handle compliance changes, patient growth, and evolving CMS requirements with ease.
Now is the time to embrace automation, stay compliant, and get paid faster. Is your agency ready to take the next step?
Frequently Asked Questions (FAQs)
If a home health agency fails to comply with RCD requirements, it may face penalties, including payment reductions or even loss of Medicare certification. Agencies must stay informed about the rules and adhere to them to avoid negative consequences.
Pre-Claim Review: Documents are submitted before billing to prevent denials.
Post-Payment Review: Claims are reviewed after payment; non-compliant claims may be denied or recouped.
AI can automate document preparation, submission, and tracking, reducing manual workload by up to 50–70%, speeding claims processing and improving accuracy.
AutomationEdge CareFlo automates the entire RCD workflow—from document collection and pre-claim submission to approval tracking. Its AI bots ensure faster validation, accurate data entry, and complete compliance with CMS requirements. By using CareFlo, agencies can reduce administrative burden, cut operational costs, and speed up reimbursement cycles.