CMS recently issued a Change Request (CR) 11258 to update sections of Chapter 11 in the Medicare Claims Processing Manual to CMS. Starting in July 2022, MACs will have new system edits to prevent gap billing between hospice transfers. Currently, there is no mechanism in place to prevent gap billing. Since hospice transfers must occur on the same day, there cannot be a break in hospice care or a gap in billing. The MLN also provided an article explaining the reason for the change request and expectations for hospices. Key Points:

  • Transferred aren’t allowed from the same provider (i.e. same CCN) even if the patient is transferred to a sub-unit,
  • Patients can change hospice only once per benefit period (60-day or 90-day) and when they do transfer, they continue the same benefit period
  • The individual or representative must file, with both hospices, a statement including the names of the two hospices and the date change is to be effective
  • The “from date” for the receiving hospice and must be the same as the “through date” for transferring hospice
  • If a patient is transferring from outside the service area and can’t arrange care on the same day, the hospice may discharge the patient ending the patient’s current benefit period and requiring re-election of hospice to begin a new period
  • The hospice transfer will be rejected if it does not occur immediately.
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Nicole Schings is the Director of Member Services and Business Development. Nicole joined the association in 2018, and oversees our Member Services program, our Partnership and Associate Member relationships, and our online education system. A graduate of Washburn University, Nicole uses her 22 years of experience in the association world to enhance the support of our members, problem solve their issues and bring new partners into the LeadingAge Kansas family. Outside of work, Nicole is passionate about geocaching and moments spent with her dog, Blu. You can reach Nicole directly at 785.670.8048.