Understanding hospice billing requirements is critical to maintaining compliance and avoiding disruptions in patient care. When a hospice patient is discharged alive or elects to revoke their hospice benefit, the provider must submit a Notice of Termination/Revocation (NOTR). In any situation where a patient leaves hospice without passing away, whether through discharge or revocation, a NOTR is required. This notice must be filed with the Medicare Administrative Contractor (MAC) within five days of the patient’s live discharge, including cases involving revocation.
The Notice of Termination/Revocation serves a few important purposes. It helps ensure the patient can continue accessing prescriptions that may have previously been covered under the hospice benefit. It also clears the way for the patient to re-elect hospice care with another provider, allowing that new hospice to submit a timely Notice of Election (NOE) within the required five-day window, without being affected by a delay in filing the NOTR.
The only time a NOTR is not required is when the hospice submits the final claim for a patient who was discharged alive within that same five-day timeframe.
On March 24, 2026, Palmetto GBA released a memo addressing Notice of Termination/Revocation (NOTR) requirements and reinforcing that agencies are obligated to submit them. Communications like this typically signal a broader trend, and in this case, it appears to indicate that NOTRs are not consistently being filed in accordance with requirements.
For those who aren’t directly involved in billing, you might be wondering how this issue occurs. Currently, the NOTR is not tied to any reimbursement, meaning there is no direct penalty if it isn’t submitted within the required five-day timeframe.
However, failing to submit the NOTR can prevent a subsequent hospice from filing a timely Notice of Election (NOE). While exceptions, such as use of the KX modifier, may eventually allow the NOE to be processed, it should not reach that point. This has long been a requirement, dating back to when NOE regulations were first implemented. It’s strongly recommended that you work with your revenue cycle team to confirm that NOTRs are being submitted within the required five-day timeframe whenever a patient is discharged alive.
If you need support with hospice billing services, Healthcare Provider Solutions has extensive experience providing outsourced hospice billing services, and we would be happy to assist you. Please reach out to us.
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