Facebook Live Presentation – Q&A About NOA’s

A Team of panelists from Precision Medical Billing (PMB) answered specific questions presented in the PDGM Facebook Group about NOA’s.  In addition, the PMB experts provided helpful tips about NOAs throughout the live presentation.


Petria McKelvey—CEO, Precision Medical Billing

Sue Brooks—Director of Billing and Client Services, Precision Medical Billing

Rosie Baker—Revenue Recovery Supervisor, Precision Medical Billing

Here are the questions and the answers as asked and answered by the PMB subject matter experts and the tips provided.

Tip #1: Keep up with the updates and news regarding the NOA for your MAC for these first couple of months, many changes, and issues with reason codes that NOA fall into and cannot process.

Question #1: Patient was admitted 8/6/2021. NOA was sent 1/2/22, rejected by MCR with the error code. We are planning on leaving the claim as is and then submitting the final with the error code in comments. In the meantime our EMR is alerting us to send a NOA with TOB AR. They state this is what has to be sent every 30 days as a place holder since there are no RAPs(322). My understanding was on admission the NOA(32a) is sent, and then no claims need to be submitted until discharge. Of course I didn’t understand how we would receive payment if we aren’t submitting any claims…. After reading today I think we should be sending NOA(32A) then a 329 every 30 days. It looks like the 320 was redesigned to be an addendum to the 322?  My concern with this I was always instructed to not submit a 329(final) until we have all the orders back signed and all documents are completed. Are we still being held to those regulations but only prior the FINAL 329 being submitted?

Response: Bill 32 A is what we submit for our NOA’s, and apparently, they also told their customers to submit a NOA every 30 Days. That is totally not true! Our RAPS in 2021 we would submit every 30 days, every billing period. NOA’s for 2022 are only submitted when you admit a new patient!

So, the exception to that, just to make it a little more difficult for us moving into 2022 is that if you had a patient on service in 2021 and they were going to continue on service you did have to submit a one-time NOA. You would submit that NOA with an artificial admit date, and that date would be the day of the first billing period in 2022. Not the first episode, but the first 30-day billing period.

So, every patient of yours would just get 1 NOA submitted either on an admission in 2022 or if they are an existing patient moving into 2022 you would still submit that one time NOA with the artificial admission date.

Now if you would discharge a patient, then re admit them, then that would be a new admit, and you would submit a new NOA for that new admission.

The second piece I broke down of this question was this person was under the understanding that the NOA being submitted on the admission but then no claims to be submitted until the patient is discharged. I don’t know how the agencies would stay in business if they are waiting to discharge patients before they bill for their services. That is totally not correct. The timing around the final claims has not changed in 2022. You should submit final claims after each billing period, that’s every 30-days. Please don’t wait until your patient is discharged!

You guys need to get that money in the door as quick as you can.

The other piece that this person posted was their concern that they have been instructed not to submit a final claim until all their orders are back and all documents completed. The requirements around when to submit your final claims have not changed, so that is the same going into 2022. Orders, plan-a- care, 45, oasis, your visit, all of that remain the same. All of that needs to be completed before you can submit that final claim. So, a lot of the EMR’s have flags around that to quickly show you what’s been completed what hasn’t. It’s either in a claim que or data dashboard to help you easily see which claims are ready and which ones aren’t.

Question #1A:

  1. In the meantime, our EMR is alerting us to send a NOA with TOB AR. They state this is what has to be sent every 30 days as a place holder since there are no RAPs (322).   
  1. My understanding was on admission the NOA(32a) is sent, and then no claims need to be submitted until discharge. Of course I didn’t understand how we would receive payment if we aren’t submitting any claims…. After reading today I think we should be sending NOA (32A) then a 329 every 30 days. 
  1. My concern with this I was always instructed to not submit a 329 (final) until we have all the orders back signed and all documents are completed. Are we still being held to those regulations but only prior the FINAL 329 being submitted?

Rosie’s Response: As we all know every software is having some kind of glitch with NOA’s for 2022. So you want to make sure that what you have in your software and the information of the patient demographic and also your insurance is something that matches with the information in DDE. If it doesn’t you are going to have an NOA that’s going to come back to you.

Sue’s Response: You can’t just rely on your EMR Right now. You have got to verify that what you think your EMR is submitting actually made it to the payer the way you think it did.

Tip #2: Always compare the information from your billing software with the information that was received in DDE.

Question #2: Does anyone know how Aetna Medicare is handling the NOA? I was told by member services that as of 1-1-22 they will require the one-time NOA/32A however when my first one came back it says they don’t have all the needed info and to resubmit with the correct type of bill. Any guidance with this company is appreciated!

Sue’s Response: This is a concern about Aetna Medicare NOA’s. That is true what they were told from member services as of 1/1/21 Aetna Medicare will require the Noa. But it looks like we’re getting them returned with some type of denial or error.

So, both Aetna and MyNexus are requiring NOA’s. I’ve seen NOA’s being submitted, and I’ve seen them come back processed on a remit without any problems from both payers… So, I know they are processing NOA’s.

The Reason why I lumped MyNexus in there with Aetna, a lot of you probably know MyNexus maybe from authorizations, they have taken over the process of handling authorizations for several different payers Aetna, Humana.

They have also started taking over processing of claims for Aetna patients. Not everywhere in the country, but the southern area of the United States they have taken over the actual processing of claims. In the Northern and Eastern I don’t think it’s there yet. But it’s coming so keep an eye out for your Aetna patients. Eventually they may take over processing claims for Humana too but I haven’t seen that start yet. So if you are having your NOA’s returned from Aetna the first thing I would do is make sure they are being submitted correctly. Don’t trust your EMR to be handling these correctly for you. I’ve seen some EMR’s where the Medicare advantage claims aren’t being created correctly or we can’t even get them out of the EMR because there Is some type of error or flag on them that Is not accurate. We have had to manually key some of Medicare vantage NOA’s as well. If the claim looks correct, if you feel like what you are submitting is correct then the next thing I would suggest is to check eligibility for that patient. Does that patient truly have a Medicare vantage plan. Maybe it’s a PPO, HMO, some type of commercial plan that doesn’t require the NOA. And, I would check how you are contracting with the payers. There are contracts that are visit based and you get paid per visit.  And if you have a contract with Aetna or any other payer that’s a per visit contract, you have allowable for each visit. Sometimes that holds true even for Medicare advantage plan. That you would still bill on a Medicare vantage plan on a per visit criteria instead of episodically. So those are the things that I would look at if you’re having your Aetna Medicare NOA’s or MyNexus NOA’s returned to you.

Petria’s Response to Sue: You made a point about keying them directly even the managed care ones. So you may want to elaborate on that, How do you key in Medicare advantage claims directly into that payer. But some payers do allow for you to key directly into their system right?

Sue’s Response: There is probably a couple ways you could do it. What we have is a clearinghouse. We submit all of our nontraditional Medicare claims for most of the clients we handle. So we can key a claim from scratch directly into our clearinghouse if needed. Just like you can key it directly into DDE for your traditional Medicare. There is also payer portals like Petria mentioned where if you don’t have a clearinghouse or are not set up with one. There are a lot of payer portals where you can enter a manual claim directly in the payer portal.

Question #3: I checked our WW999 NOA in Suspense and it moved to Terminated with a Reason Code 19960 which is there was a Condition Code 15 that appeared in the Claim which I did not put in there. Does anyone have the same issue? I have not seen the problem in the Claims log of Palmetto. Would appreciate your reply.

Petria’s Response: This was addressed specifically on Palmettos’ claim issue log. It has recently been resolved. You weren’t the only one putting this claim code 15 on our claims. Yeah, you were not the only one. They were trying to put it in a suspense area then they terminated … well the resolution came out on the claim issue log. It’s been resolved 1/28/22… really recent and they are saying that if you did have claim and it was here and it was past 5 days, that on your final claim in the remarks you need to put CC15 release and then that should allow your final claim to go through.


Put that in the remarks if this particular WW999 NOA Suspense reason code 19960 was the reason for your NOA being late, then that is what they want you to put on the final claim.

Rosie’s Response: I think it’s a very good tip that we go ahead and make sure that the wording that is put on the final claim is correct. Because if you do not address It that because of the reason 19960 is the reason my NOA is late. It’s hard for Medicare to determine once your final is going to process. But if you automatically put that information on there on the remarks and final, this is the reason my NOA is late they will immediately see that and will consider it.



If you want to receive future updates, event announcements and the PMB newsletter, please click here and ask to be added to our email list.

Tip #3: In HETS, run eligibility before admitting a new patient to verify the patient is Medicare primary. If the patient is not Medicare primary, an NOA may not be needed.

Sue’s Response:  In HETS for your Medicare patients it’s important that you run eligibility before admitting your new patients. You want to verify that Medicare truly is the primary for that patient. Obviously If Medicare is the primary you are going to submit and NOA. But if Medicare is not the primary, if they have a different Medicare advantage plan, or even a commercial plan for primary. An NOA won’t be needed for a commercial plan but may not even be needed for your Medicare advantage plans depending on what plan it is.


Question #4: We, like many, had failed NOAs due to MCR rejecting them before they got into the CWF. What remark should I put on the replacement NOAs I am keying into DDE so we don’t get the late penalty.

Rosie’s Response: NOA’s do not have remarks if you have already submitted your NOA the first time and it is rejected go ahead and enter your second NOA. Do not suppress, do not delete, or do not get rid of your first one because that is what Medicare is going to look at when they process your final. So it’s going to come down to your final, once you submit that second NOA and you submit your final for that period, then you put on remarks. And you are going to have to add a modifier for your exception to that NOA, so when your final processes it won’t have a QF which means that your final has a PENALTY!



Question #5: Optum VA-I am finding anything on VA site or Optum stating 2022 changes. Is there anyone who has these links handy that could direct me in now I should correctly be sending these claims in. Noa/rap. Final only (which how does that ever work)..etc? 

Sue’s Response:Optum VA does not need an NOA. They have that posted on their portal/ payer website. Optum VA CCN NOA’s are not needed in 2021. Final Claims should be, still submit your 329 type of bill, your final claim every 30 days. But an NOA is not needed.

The VA it talks about the VA site. I don’t think there would be many claims submitted directly to the VA for processing anymore. Most of them are going to the Optum VA CCN. But if you do have some claims that need to be processed by the VA. The VA has always been a visit-based claim not episodic. So, because it’s visit based an NOA is not needed it’s just every visit. You can submit claims weekly or biweekly or however you want to submit them but it is visit based claims if you are submitting directly to the VA.

Tip #4: Corrections of the NOAs MUST be sent within 2 days or the exception will not be accepted.

Petria’s Response: Corrections of the NOA’s MUST be sent within 2 days or the exception will not be accepted.  You must follow it, you have to follow up, you have to watch it. Once you put them in just don’t leave them alone. You need to put them in, watch them, correct them, then go ahead and put it back in. Go ahead and make your corrections and put it back in as a correction.

Sue’s Response: Our team looks at the NOA’s we have submitted at least everyday. If there is something that is really close we’ll look at it more frequently. But once you submit it like Petria said, you cannot just assume it’s going to process. You have got to follow up and look at it as soon as it is returned to you, as soon as there are corrections needed you need to get it back out the door.

Rosie’s Response: Especially now because it is processing faster. As soon as it hits the system by the next day it will change from that status location of being 9000 to a status location of being 9999 and once it’s on there you need to go ahead and do your corrections because it starts looking really closely to that final exception. That’s where you do the corrections of your NOA on your FINAL.


Rosie’s Response: As it comes down the status it really… It really doesn’t come down to anything more than does it have a remit date, it processes. It actually comes down to that status location. Each status location means something, so if you are not looking at that status location, saying I’m just going to wait until I get that receive date let’s say 2/15/22. You have already lost 4 days.


Question #6: I have a 32A (NOA) that RTP due to another HHA hasn’t submitted their Discharge yet. Our notes state the previous Agency DC’d on 12/3/21 and our NOA is dated 01/08/22.
Anyone know how we handle these, so they’re not considered late?
Thank you advance for any information that you can provide. 

Rosie’s Response: First of all, if the other agency discharged on 12/3/21 your NOA should be okay to submit. Now you can submit your NOA with a condition code 47. That is the only thing that is valid on an NOA is a condition 47. So, if the other agency has not done the discharge yet but you have already admitted the patient. You can go ahead and add that condition 47 to your NOA so it can go ahead and process.

Petria’s Response: Basically, the NOA is like the RAP where we could put a 47-condition code if it’s for that reason that the NOA didn’t go through you are allowed to still use condition code 47 is what Rosie is saying. If that is the reason for an overlap you can still use the 47.



If you want to receive future updates, event announcements and the PMB newsletter, please click here and ask to be added to our email list.

Question #6A: What about the final? I was told no 47 on the final and bill w/kx modifier for exception of the late rap.

Will adding the remarks will trigger it to get reviewed by a person, instead of just cycling through?

Rosie’s Response: I think we just covered this one. On the final is where you are going to put your modifier with your 47 and the remarks. So, this was something that Petria was addressing that you want to do those modifiers on your final, and your remarks, also with that condition code 47 that was included in your NOA.

Question #6B: Pertaining to an NOA

I tried to resubmit one with the 47 code thinking that if it went to P status, I could add KX and remarks when I bill the FC. Sadly, it did not to into P status, it went into S then after a week T status with the same Reason code.

I’m using NGS MAC, which MAC are you working with using this solution?

Rosie’s Response: If your final went to the same reason, it was overlapping and you still put a 47 on there, you put the modifier, and you also put your remarks and it still said its overlapping. Then there must be another reason other than you’re overlapping. So, again I’m going to go back and say do your eligibly. Because your eligibility is going to go ahead and tell you if it is a real overlap or you have an overlap of another agency, facility, hospital, etc. It can be all of the above so if it’s any of those you’re going to have to look at those factors and then you also want to see if the patient is still covered with Medicare only. Is there another insurance involved? So, you want to look at all those factors and by doing that you would do the eligibility and they will tell you everything exactly. To go back and address this T status.


If you want to receive future updates, event announcements and the PMB newsletter, please click here and ask to be added to our email list.

Tip #5: Lupa needs an NOA

Sue’s Response: Regarding NOA’s nothing changes you need to submit an NOA even if your patient is expected to be a Lupa patient. If it’s a new admission to your agency you must submit the NOA, there is no exceptions for that.

Petria’s Response: You need an NOA to match that Lupa.


Ben Cabrera Question #1: a patient was hospitalized, on day 15, then came back on day 23, since the reason we are seeing the patient is now different from the original F2F post admission, we re-admit the patient with a new SOC instead of resumption. with that new SOC can we submit a new NOA with a code 47 or what’s the process? thanks

Rosie’s Response: With the resumption of care, it is really an option to discharge the patient once the patient has been admitted to the hospital. Being that these patients 30 days are not over yet, you do have the option to discharge or not discharge. I don’t know if that was done in this case, and if it wasn’t discharged then you do not need another NOA. If you did discharge, then yes, you do need a new NOA because the regulations for the NOA is you use it until a patient is discharged.  So, if you did not do a discharge to this patient that went to the hospital you do not need an NOA. Even If the face-to-face post is different that is something that is going to be linked, with the information that you submit to Medicare. So, I will not suggest for you to do an NOA with a 47.


Petria’s Response: The only time that you need to do the NOA in the regulations is if this is a brand-new start of care. If this is not a brand-new start of care you don’t need an NOA. So, if you didn’t discharge them and did a resumption, a resumption is not a start of care. It’s a resumption so it depends on… if you did a start of care you need an NOA.


Gerry Manarpiis Gaoat Question #2: Hi, Gerry from Merrillville, IN. For those NOAs that were RTPd due to the MCR issue and been resolved, the 329s were submitted without the remarks cc 15 released. It seems the 329s were paid with the late penalty, what are we going to do to correct it?

Rosie’s Response: I have a suggestion for you, according to what Medicare is letting all providers know when you do have claims that give you a late penalty. A QF on the final claim they are only accepting anything that you cannot control. So in this case because it is condition 15 and it’s something that you couldn’t control, you can go back to your final. Submit it with a modifier go ahead and put your remarks on there and say that it was due to the condition code 15 that Medicare couldn’t fix.

Petria’s Response to Rosie: Are they doing it as a 327 as a correction claim?

Rosie’s Response to Petria: If it RTP’d it’s not going to be a 327. That 329 will change to a 327 you are correct Petria.

Petria’s Response: So, do a correction claim Gerry and in your remarks go ahead and add that verbiage about how the cc was late due to the cc 15 release. Right Rosie is that what you were trying to say?

Rosie’s Response to Petria: Correct make sure you put that modifier on there and put it on your remarks.

Staci Wade Snapp Question #3:We are still having issues with BCBS Medicare Advantage denying NOA’s for incorrect bill type. Any suggestions? Our rep told us she doesn’t know anything about Medicare billing

Sue’s Response: Each BlueCross Blue Shield is run independently at the state level. So each state Bluecross Blue Shield will have different rules. So depending on your state it could be different than other states. I haven’t seen any of the states we deal with with BlueCross BlueShield requiring NOA’s right now. I haven’t seen any notice from BlueCross Blue Shield at the state level that are going to require an NOA. I would check your payers website and see if they have any instructions there. You could attempt to submit a RAP and see If that gets processed.

Petria’s Response to Sue: I think Staci is Louisiana, Baton Rouge. So you have to try things Staci like Sue is saying. Try to submit it. Did you try submitting a 329 without an NOA at all?

I would try that, or go back to the RAP. Because like we said they are not ready, their systems aren’t ready an who knows what they are going to accept and when they will be ready. You just have to stay on top of them. I tell everybody about billing. It’s all about how follow up, your success is going to be about your follow up. Sue and I have gone back for a client in Pennsylvania from 2020 that we are finally getting paid on. But guess what we never stopped. We don’t stop, don’t stop won’t stop!

So, Staci just stay tenacious you got to get it girl and stay on top of it. It might not be until June. I am sorry, but don’t you let them keep your money, that’s the bottom line.