Hospice Experience with NOE/NOTR Requested

HEALTHCAREfirst Encourages Hospice Providers to Participate in NAHC/NHPCO Survey.

Since the inception of the new timely filing rules for Hospice Notices of Election and Termination/Revocation (NOE/NOTR), hospice care providers have experienced issues that make filing NOEs and NOTRs cumbersome, or lead to delays in posting NOE or NOTR data to CMS systems, which results in loss of revenue. I have continued to receive questions from providers about the DDE filing system, the inability to batch and transmit NOE/NOTR data directly from electronic health records and the inability of FISS to accept NOE/NOTR electronic files.

The following comment was posted by CMS in the Fiscal Year 2015 Hospice Wage Index and Payment Rate Update on page 27:

“Before the implementation of the HIPAA transactions and code sets standards in 2003, CMS accepted hospice NOEs via Electronic Data Interchange (EDI) batch submission using the UB–92 flat file claim format. HIPAA implementation eliminated the UB–92 flat file format for claims processing, replacing it with the 837 Institutional (837I) claim transaction. The 837I format requires reporting at least one delivered service and other data elements that are not appropriate to an NOE, so an EDI claim transaction could no longer be used for this purpose. At that time, a great majority of hospice NOEs were already being processed via Direct Data Entry (DDE) into Medicare claims processing systems. CMS determined that DDE submission of NOEs met the business needs of Medicare and most hospices. While many hospices have now adopted electronic health record technology that could facilitate the creation and submission of electronic NOEs, no standard for such submission currently exists. There would be significant implementation challenges associated with creating an interface between any new non-claim format and Medicare claims processing systems. CMS plans to explore options to resume electronic batch submission of hospice NOEs in the future and welcomes input from the hospice industry regarding how electronic submission of NOEs could be feasible.”

The National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO) have developed a survey to gather more in-depth information about the impact of the requirements on hospice programs to help quantify the problems associated with the NOE/NOTR requirements. HEALTHCAREfirst recommends Hospice providers review the NAHC article and participate in the survey. NAHC announced that the deadline for survey participation is Friday, August 28th and have requested that each hospice only respond to the survey one time.

August 24, 2015

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