by editor | Sep 12, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Documentation - Nurses, Financials, Hospice 101 - Nurses, Intake, Medical Records, Metrics and KPIs, Notice of Election, Rules and Regulations - Nurses
A hospice must file a Notice of Election (NOE) within five days after the beneficiary’s hospice admission date.
What is considered timely filing of an NOE?
For an NOE to be considered timely:
- The NOE must have a receipt date within five calendar days after the hospice admission date
- The NOE must process and finalize in status/location P B9997
For example:
- Patient admitted on 5/8
- NOE submitted on 5/13
- NOE processed on 5/27
To be timely, the NOE must have a receipt date of 5/13 and the NOE must subsequently process (P B9997)
However, if the NOE is not filed timely, Medicare will not cover and pay for the days of hospice care from the date that the patient is admitted until the date the NOE is submitted and accepted. For example:
- Admission date: 5/1
- NOE receipt date 5/10
- NOE processed 5/18
Non covered days: 5/1 through 5/9 (one day before NOE receipt date)
- Admission date 5/1
- NOE receipt date 5/10
- NOE processed 5/18
Non covered days: 5/1 through 5/9 (one day before NOE receipt date)
What happens if a hospice must resubmit an NOE due to errors?
Sometimes an NOE is submitted but it is not accepted due to a need for corrections. The NOE is “RTPd” (Returned to Provider) and is then resubmitted by the hospice. The date that the NOE is resubmitted by the hospice is considered the submission date.
How should a hospice file a claim if the NOE was filed late?
If a hospice has a late NOE, the claim must be filed showing the late filed NOE. It must also show occurrence code OSC 77, indicating the non covered dates. The claim will have two rows, one row for the non-covered days and one row for the covered days.
See Submitting Claims for Untimely NOEs for more details on billing when NOEs are untimely.
For more information on submitting claims, read some of our posts here Hospice Keys Billing Blogs
by editor | Sep 12, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Financials, Metrics and KPIs, Office Setup, Rules and Regulations - Nurses
A Medicare Administrative Contractor (MAC) is a private health care insurer that has been awarded a geographic jurisdiction to process Medicare Part A and Part B medical claims for Fee For Service (FFS) beneficiaries.
CMS relies on these contractors to serve as the primary operational contact between the Medicare FFS program and the health providers enrolled in the program.
MACs are multi-state regional contractors who are responsible for administering Part A and Part B claims.
What types of MACs are there?
There are two types of MACs: Part A/B MACs and DME MACs.
Hospice claims are administered by Part A/B MACs. Part A/B MACs process about 95% of all FFS claims.
There are 12 Part A/B MACs.
Four of the MACs specialize in processing claims for hospice and home health providers
What geographic areas do each of the hospice and home health MACs cover?
The following map shows the geographic regions that each of the hospice MACs is responsible for administering.
What activities do MACs perform?
MACS perform a number of activities including:
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Provider Enrollment
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Claims processing, payment, and payment notices
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Provider customer service (but not beneficiary customer service)
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Audit provider cost reports
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Respond to provider inquiries
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Audit payments and review medical records
How are MACs measured and how well do they perform?
Each year, CMS evaluates MAC performance against specific metrics in eleven functional areas. MAC performance quality has been consistently improving since CMS began measuring MAC performance. Average MAC performance has increased from 62% to 93% since CMS began measuring MAC performance.
Print ‘n take hospice keys
- Seeking to contact your MAC? Here’s their contact information
hospiceKeys - CMS MAC contact
Download
- A map of MAC regional jurisdictions
hospiceKeys - CMS MAC
Download
Where can you find more information?
This PowerPoint from Medicare Learning Network provides more helpful information about MACs: MLN MAC PowerPoint
by editor | Sep 8, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Financials, Intake, Notice of Election, Rules and Regulations - Nurses, Rules and Regulations - Office Team
What is a Notice of Election?
When a Medicare beneficiary elects hospice services, the hospice must complete an election notice with the beneficiary and file a Notice of Election (NOE) with Medicare.
When must a Notice of Election be submitted?
A hospice notice of election must be submitted and processed prior to submitting the first hospice claim. Beginning October 1, 2014, Medicare has implemented a requirement that the hospice agency must file a NOE within 5 calendar days after the date of the hospice election notice.
In addition to filing the NOE, the NOE must be accepted by the Medicare claims system. For an NOE to be accepted, it must be a “clean submission.” That is, the NOE may not have any errors.
If the NOE has any errors, it will be returned to the provider (RTP’d) for correction. When the provider corrects and resubmits the NOE, the NOE will be assigned a new received date. This new date will be used to establish timely filing with respect to Medicare’s five day requirement.
There are three ways that a hospice provider can submit an NOE
– Using Direct Data Entry (DDE):
DDE is a real time Fiscal Intermedicary Shared System (FISS) application that gives hospice providers the ability to submit claims, monitor the status of claims, and correct claims. It can also be used by providers to monitor claims and requested documentation and to check beneficiary eligibility information.
Providers can manually enter the NOE into DDE via the different relevant screens.
– Submit electronically:
This option became available effective January 1, 2018. The hospice industry requested requested that Medicare implement NOE submission via Electronic Data Exchange (EDI), as this would eliminate keying errors associated with NOE (and thus reduce the number of NOEs that were RTP’d for keying errors since the data for the NOE could be exported directly from the patient’s electronic medical record). Note that NOEs should not be batched with claims
– Paper submission on UB-04 claim forms. .
Where can you find detailed information about completing the NOE?
A helpful job aid has been created that provides details on how to complete the notice of election, with details on the different data requirements depending upon the method of submission: Palmetto NOE job aid
by editor | Aug 4, 2022 | Billing, Billing - General, Compliance and Regulatory, Compliance and Regulatory - Directors, Documentation - Nurses, Financials, Intake, Patient Care, Rules and Regulations - Nurses, Rules and Regulations - Office Team
Prior to the third hospice benefit period, and prior to each subsequent benefit period, a hospice physician or nurse practitioner is required to have a face to face encounter with the hospice patient to recertify that the patient continues to be Medicare eligible for hospice benefits. The face to face encounter must occur within 30 calendar days prior to the start of the third benefit period and each subsequent benefit period.
The face to face encounter is necessary to recertify that the patient remains eligible for Medicare hospice benefits. If face to face encounters are not performed timely, the patient is is no longer hospice eligible. The hospice may continue to provide hospice services to the patient but may no longer continue to bill Medicare. Instead, the hospice would need to assume all financial responsibility for the patient until such time that the hospice is able to reestablish patient hospice eligibility. The patient may be readmitted to hospice once hospice eligibility criteria are once again met.
What if there are exceptional circumstances that cause the hospice to be unable to timely complete the face to face encounter?
What are exceptional circumstances?
If a patient is admitted and is in the third benefit period or later, the hospice agency may be unable to perform the face to face encounter prior to the start of the benefit period.
For example, if the patient is an emergency weekend admission and the nurse practitioner or hospice physician is unable to meet with the patient prior to hospice admission. The patient is only seen the following Monday.
Another exceptional circumstance may be where the CMS data system is unavailable and the hospice agency is unaware that the patient is in the third or later benefit period.
In these documented exceptional circumstances, the face to face encounter is considered timely if it is completed within two days after admission.
In addition, if the patient dies within two days of admission, the face to face encounter is considered complete.
Where can you get more information?
Details on Medicare Face to Face encounter requirements: Medicare F2F encounter requirements
by editor | Aug 4, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Documentation - Nurses, Financials, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Nurses, Hospice 101 - Office Team, Intake, Patient Care, Patient Eligibility, Rules and Regulations - Nurses, Rules and Regulations - Office Team
A hospice face to face encounter is a step in patient recertification beginning with the third benefit period and each benefit period thereafter. The goal of hospice face to face patient encounter is to encourage greater involvement of the physician in the care of patients who have been on hospice for an extended period of time. These patients will require a face to face visit from the physician or from a hospice nurse practitioner who will determine continued hospice eligibility. The face to face encounter is one part of hospice recertification. As such, the face to face encounter will also occur prior to recertification.
When must a face to face encounter take place?
A face to face encounter must take place within 30 days prior to the start of the patient’s third benefit period. It also must take place within 30 days prior to each subsequent benefit period. The requirement for a face to face encounter considers the patient’s hospice stays across all hospices. For example, if a patient spent 100 days at Hospice Agency A and then switched to Hospice Agency B, Hospice Agency B will need to conduct a face to face encounter within 50-80 days of the patient’s admission. That is, when the patient is admitted to hospice B the days of counting toward the face to face encounter begin from the first day that the patient entered any hospice care.
How will I know if the patient has had prior hospice care?
Upon admitting a patient, the hospice agency should check the Common Working File to determine the patient benefit period and whether a face to face encounter is required.
Who may conduct the face to face encounter?
Either the hospice physician or nurse practitioner (NP) may conduct the face to face encounter. The hospice physician may be an employee or contracted by the hospice agency. If the NP conducts the face to face encounter, the NP must be an employee of the hospice and is not permitted to be a contractor (since nursing is a core service).
What should the recertification narrative include?
The third benefit recertification – and each subsequent recertification – will need to contain clinical findings that support continued hospice eligibility. The narrative must include an explanation of why the clinical findings support a life expectancy of six months or less.
If the physician conducts the face to face, he or she will be responsible to write the narrative about the clinical findings regarding the patient’s condition and for certifying the patient’s continued eligibility for hospice.
If the nurse practitioner conducts the face to face encounter, he or she will report back the clinical findings to the interdisciplinary team as well as to the hospice physician who will certify as to whether the patient is eligible for continued hospice care.
The recertification requires an attestation
The clinician who conducts the face to face encounter must attest in writing that the face to face encounter was performed with the patient and must include the date that the encounter occurred.
If an NP conducts the encounter, the NP must attest that the clinical findings were sent to the certifying physician.
The attestation is signed and dated in is included as a separate and distinct section of the recertification. The recertification also clearly notes the benefit period dates for which the recertification applies.
What happens if the face to face does not take place timely?
If the face to face does not take place, the patient is considered no longer considered terminally ill and therefore is not eligible for the Medicare hospice benefit. The patient remains ineligible until such time that the face to face encounter occurs and it is confirmed that the patient is once again hospice eligible. The patient must be discharged from the hospice but can be readmitted once the face to face encounter occurs. Medicare does permit the hospice agency to continue to provide services at the agency’s expense until the patient’s eligibility is reestablished. However, this care will be provided outside of the Medicare hospice benefit.
by editor | Jul 25, 2022 | Accounts Receivable, Billing, Billing - General, Financials, Metrics and KPIs
Who are Hospice Agency Payers?
A payer is the company of government agency that pays the provider, i.e., the hospice agency, for the medical service that is administered to the patient.
For most hospice agencies, Medicare is the primary payer for hospice services. See, for example, this study published by Bazell et al., 2019, https://bit.ly/3RS805r. The characteristics of payment vary by payer. As such, an agency should understand the distribution of its revenues and receivables across different payers. In addition to understanding the breakdown of total receivables, the agency should look at distribution of receivables by payer – further broken down by aging bucket.
Expected time to be paid on a claim varies by payer. For example, payment for a Medicare claim is usually received within 14 days of the date the claim is submitted. A claim submitted to a commercial payer will take longer and further varies by the commercial payer. It is important to monitor time until payment is received for each payer. Delay in payment is an opportunity to quickly identify if there is a billing error that needs to be corrected. Or, there may be an opportunity to improve the billing and collection process that will result in an increase in speed of collections.
It is also useful to compare your agency’s metrics to industry standards. Metrics that are worse than industry standards could point to areas of the collections process that could benefit from process improvement.
Aging Accounts Receivables for Medicare and Commercial Payers
The following graph shows aging accounts receivable for the Medicare payer. As we see from the graph, over 90% of the receivables are less than two months old.
In contrast, here we can see the distribution of aging accounts receivable for commercial payers for the same hospice agency.
In contrast to the Medicare accounts receivables, here only 43% of the receivables are less than two months old. 25% of the receivables are between four and eight months old. More significantly, more than 25% of the outstanding receivables are more than 12 months old – a sign that there may be a high number of receivables that may have to be written off.
What is the key takeaway?
Different payers have different payment patters and different rules for timely submission of claims. Hospice agencies need to have a good understanding of the distribution of their claims and the distribution of their outstanding accounts receivable to reduce the likelihood of write-offs.
