Eli's Hospice Insider

Tip: Don’t let coding changes delay your NOEs.

Every day you’re late filing a patient’s Notice of Election costs you money, but many hospices are still less than familiar with the ins and outs of NOE submissions. Pay attention to advice from one Medicare Administrative Contractor to help you out. 

MAC Shoots Down This Excuse For Late NOEs

Don’t expect your MAC to let you off the hook for NOE filing deadlines based on a transmittal revision date.

The requirement to file the Notice of Election within five days of election took effect Oct. 1, 2014, stresses HHH MAC CGS in a recent post on its website. “Some provider documentation being submitted with exception requests include a copy of Section 20.1.1 of the Centers for Medicare & Medicaid Services (CMS) Pub. 100-04, Ch. 11. Section 20.1.1 of that manual currently shows (in red font), ‘(Rev. 3118, Issued: 11-16-14, Effective: 10-01-14, Implementation: 04-06-15)’. The provider documentation implies that their claim was before the 04-06-15 implementation date and therefore does not apply to the CR 8877 timely NOE requirements,” CGS says.

“Please note that the Rev. 3118 (the Transmittal number) is not related to the requirements in CR 8877; therefore, in this case the exception request is denied,” the MAC explains.

By the way: Yelling at the customer service reps at your MAC isn’t going to help if your NOE exception request gets turned down, CGS stresses.

“Exception requests determinations are made by the CGS Claims department,” the MAC says in a message to providers. “The Customer Service Representatives (CSRs) in Provider Contact Center do not make those determinations. If your exception request is denied, the noncovered days can be appealed by following the Medicare Appeals Process.”

Remember: To qualify for an exception to the five-day Notice of Election timely filing deadline, circumstances causing the problem must be out of a provider’s control, CGS emphasizes.

Be alert: Providers are faxing exception requests to the wrong fax number, CGS adds. For details on the exception request process, see www.cgsmedicare.com/hhh/education/materials/requesting_exception_untimely_noes.html.

Examples of granted and denied exception requests are online at www.cgsmedicare.com/hhh/education/materials/examples_denied_granted_exceptions.html.

Heads Up: System Doesn’t Check For NOE-Claim Coding Match

Don’t let ICD-10 cost you when it comes to NOEs. CMS doesn’t have an edit that compares the principal diagnosis on the hospice Notice of Election with the principal diagnosis on a subsequent hospice claim, points out the National Association for Home Care & Hospice in its member newsletter.

Don’t: “Some hospices have been making corrections to the NOE when the principal diagnosis code on the claim does not match that of the NOE,” NAHC notes. “The correction to the NOE in this case requires backing the NOE out of the system, which in almost all cases results in an NOE that was not filed timely. This equates to a loss of revenue for the hospice.”

Do: “The only time a correction needs to be made to the NOE is when the information on the NOE is actually wrong at the time of the submission,” NAHC emphasizes. “If the principal diagnosis code identified at admission, and put on the NOE, is later changed but was accurate at the time of admission (based upon information that was available at the time), it is not an error on the NOE and does not need to be corrected.”