Home Health & Hospice Week

New edit should clear up at least some problems occurring with transfer patients.

Medicare officials highlighted a change to eliminate an NOTR problem, but it may not be enough to ease hospices’ related billing woes.

Old way: The Common Working File allows Notices of Revocation/Termination (NOTR – Type of Bill 8xB) if the provider identifier on the NOTR matches the provider on the hospice election period, the Centers for Medicare & Medicaid Services says in CR 11049. “This occurs even if transfer notice (8xC) or a change of ownership notice (8xE) has changed the billing provider on a benefit period within that election.”

New way: A new edit going in July 1 will “ensure that only the active billing provider can submit a revocation,” CMS notes.

The claims system will reject an incoming NOTR if the provider CMS Certification Number (CCN) matches the CCN on the hospice election period, and transfer or change of ownership dates are present on a hospice benefit period, and no claims have processed within the benefit period after the revocation date, and the CCN does not match the CCN associated with the latest transfer or change or ownership date on the hospice benefit period, CMS explains.

“This requirement shall apply to both original NOTRs and submissions with action code ‘2,’” CMS adds.

This situation is fairly rare, so shouldn’t have a big impact on hospices, said a CMS official in the agency’s Jan. 16 Open Door Forum for home health and hospice providers.

However: Hospices are having billing troubles even when the transferring hospice has filed a transfer notice (TOB 8xC), two providers reported to CMS in the call. When the hospice that submitted the transfer notice submits its final claim, a revocation code is going on the election period, which won’t allow the hospices receiving the transfer to bill, they told CMS. “That shouldn’t happen,” a CMS staffer said.

Note: The CR is at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R4187CP.pdf.