CMS recently released MLN Matters SE18007 which details recent and upcoming improvements to Medicare hospice billing. Two recent improvements – Electronic Submission of the Notice of Election (NOE) and Correcting Election or Revocation Dates using Occurrence Code 56 – are summarized and additional upcoming improvements are addressed. These are:
- New Election Period File and Screen
- Benefit Periods
- Making Changes to Election Period or Benefit Period Information
- NOTR Submission Changes
- Void/Cancel Submissions
- Processing Impacts
Prior to July 2, 2018, Medicare systems tied the hospice election date to the benefit period; however, beginning on this date, when a hospice submits an NOE (TOB 8xA), an election period is created in Medicare systems that is separate from any benefit periods. Benefit periods are created only by the claim, not the NOE. The NOE receipt date will be retained on the election period permanently. If a benefit period is canceled, this will no longer remove the NOE receipt date from Medicare systems. If the election date is changed using the occurrence code 56/condition code D0 process, the NOE receipt date will not change. These improvements will reduce the number of NOE timely filing exceptions related to limitations in Medicare systems.
In the past, if a hospice made an error in the election date on an NOE the hospice had to go through a burdensome process to get it corrected and it often resulted in non-payment of some days of care. Now, in order 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. 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. This will prevent an NOE from being created while there is an active election period for the patient that has not been ended and is not being corrected.
Hospices will be able to see the election period information in a new CWF inquiry screen. This will contain only election period information and revocation information. The benefit period information will be in another CWF inquiry screen and will look the same as it did previously.
Another improvement resulting from separating the election and benefit periods is that a hospice can now process a Notice of Termination or Revocation (NOTR) without having to wait for the benefit period to be created. However, this does require the hospice to change how the NOTR is submitted, so hospices must read this article for new instructions. In fact, there are many detailed instructions for billing in this article, so it is a must-read for all billers. In addition, this article references a previous change request, Change Request 10064, which is about corrections to election and revocation dates that can be made using occurrence code 56 and electronic submission of the NOE. Both are must-read articles for billers. Please note that the use of occurrence code 56 to correct election and revocation dates only applies to election or revocation dates on and after January 1, 2018.