Eli's Hospice Insider

Don’t lose money due to corrected NOEs.

It’s essential to stay up to date on Medicare billing guidance, and a recent MLN Matters article shows you why.

June 7 MLN Matters article SE18007 reviews changes to Medicare hospice billing processes that can save hospices money and time, noted a representative from the Centers for Medicare & Medicaid Services in CMS’s July 11 Open Door Forum for home care and hospice providers.

Change #1: NOE Corrections

As of Jan. 1, Medicare began accepting electronic Notices of Election. Being able to submit NOEs electronically drastically cuts down on errors due to staffers keying incorrect information into the Direct Data Entry system, CMS notes.

Along with that process, hospices can also submit corrections to their NOEs, the MLN Matters article points out.

Old way: “If a hospice made an error in the election date on an NOE (Type of Bill (TOB) 8xA), the hospice had to cancel the incorrect election (using TOB 8xD) and then submit a replacement NOE,” CMS explains. “This would correct the election date in Medicare systems, but the original NOE receipt date was lost. When the replacement NOE was processed, it often appeared that it was submitted after the 5 day timely filing period. This in turn resulted in the need to request an exception to the NOE timely filing requirement. This was an administrative burden.”

New way: Now, “to correct an election date, the hospice can simply submit another TOB 8xA, using the correct election date as the From, Admission dates and Occurrence Code 27 dates,” CMS says. “The hospice must also submit the original, incorrect election date on the 8xA using occurrence code 56. Medicare systems use this date to find the election record to be corrected, then replaces that election date with the corrected information. The hospice must also indicate the NOE is a correction by adding condition code D0 (zero). If occurrence code 56 and condition code D0 are not both present, the NOE will be returned to the hospice.”

Plus: “The hospice can use a similar process to correct a revocation date, if the wrong date was submitted on a Notice of Termination/Revocation (NOTR) using TOB 8xB,” CMS adds in the article.

The CMS staffer said in the forum they “encourage providers to review it carefully.”

One more thing: One of the most helpful parts of this change is being able to remove a revocation that should never have been submitted altogether, the CMS source noted.

“If a revocation date was submitted entirely in error (for instance, the beneficiary actually transferred to another hospice, rather than revoking their hospice benefit), the hospice can remove the revocation date by submitting TOB 8xB with zeroes in the Through date,” CMS instructs. “The hospice must submit the original, incorrect revocation date on the NOTR using occurrence code 56 and indicate the NOTR is a correction by adding condition code D0.”

Change #2: Benefit Period And Screen Changes

The article also explains changes to the benefit period process that took effect July 2 and to the benefit screen information that went live July 9, the CMS official explained in the forum.

Old way: In the past, a “variety of processing problems” came from using a single file for the hospice benefit period and billing period, the staffer noted.

New way: Now, CMS has separated the benefit period and billing period information. It has created new benefit period screens.

Separating them provides solutions to a number of problems, including retaining the NOE receipt date even when the election date is changed; allowing the filing of revocations even when a claim hasn’t yet been filed; and keeping election periods intact even when a patient transfers to another hospice.

To ensure the new system works, hospice must “change how they submit the From date on an NOTR,” CMS stresses in the article. Those changes include:

• When there is no change in the provider number during the election, the hospice must submit the start date of the election period as the From date on the NOTR. In the past, the hospice submitted the start date of the current benefit period as the From date, so it is important for hospices to be aware of this new procedure.
• If the revocation follows a transfer, the From date on the NOTR must match the START DATE2 on the benefit period that initiated the transfer.
• If the revocation follows a change of ownership, the From date on the NOTR must match the OWNER CHANGE start date on the benefit periods. This process is to ensure that only the provider currently providing services to the beneficiary can submit the NOTR.
• In all cases, the Admission Date on the NOTR must continue to match the From date.

Note: More information about the changes is in the article at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE18007.pdf.