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Referring, Ordering, Prescribing, Attending (ROPA) Update

Date: 02/16/22

Dear Arizona Complete Health-Complete Care Plan (AzCH-CCP) Providers and Billing Staff:

The Patient Protection and Affordable Care Act (ACA) and the 21st Century Cures Act (Cures) require that all health care providers who refer AHCCCS members for an item or service, who order non-physician services for members, who prescribe medications to members, and who attend/certify medical necessity for services and/or who take primary responsibility for members’ medical care must be registered as AHCCCS providers. AHCCCS calls this initiative, and these providers, "ROPA.”

Until these acts passed, referring, ordering, prescribing, and attending providers were required to obtain and maintain a National Provider Identifier (NPI), but were not required to be registered as an AHCCCS provider. With the implementation of ROPA requirements, any registrable healthcare provider who is not already registered as an active AHCCCS provider must register or be identified as an Exception non-registerable provider*, if applicable.

AHCCCS is tying the go live date for hard edits on claim submissions to the ending of the Public Health Emergency (PHE), which currently is scheduled for mid-April 2022.  It is likely the ROPA effective date will be 60 days after the PHE ends.  All Medicaid plans in AZ will be required to follow the regulation.  

To help you identify current claims that include ROPA providers that are not yet registered with AHCCCS and will deny when ROPA goes live, the informational codes below are being included on our Explanation of Payment (EOP):

  1. EX1H* ROPA: REFERRING PROV NOT ACTIVE W/AHCCCS
  2. EX2f* ROPA: ORDERING PROV NOT ACTIVE W/AHCCCS
  3. EX2j* ROPA: ATTENDING PROV NOT ACTIVE /AHCCCS

Please review your EOP, compare to your claim(s) and reach out to these providers to urge them to register with AHCCCS as soon as possible in order to avoid future claim denials!

Resources:

If you have questions regarding the information contained in this update or need your assigned Provider Engagement Specialist’s contact information, please email AzCHProviderEngagement@azcompletehealth.com.