Maintain Billing Compliance with Hospice Transfers

Recently, the Centers for Medicare & Medicaid Service (CMS) made updates to provide clarifications in Medicare claims processing specific to hospice transfers that impact billing and are imperative for every hospice agency to know. When a patient receiving hospice services decides to transfer from one hospice agency to another, they are permitted to do so once during each certification period without formal discharge and readmission to another agency. CMS requires no gaps in services when the transfer occurs from one agency to the next. This means that transfers must be completed the same day.

What’s new?

Per regulations (42 Code of Federal Regulations CFR 418.24d), the duration of a hospice election spans through the initial benefit period to all subsequent periods without a break in service. Should the recipient choose to transfer care to another agency, this is not considered a discharge and readmission as long as the days of service do not have a gap. Billing continues daily if the service days are continuous.

Remember, both the transferring hospice and the receiving hospice can bill for services for the day of transfer. If there is a break in care from one agency to the next, CMS will consider the patient to have been discharged and the individual would be required to re-elect a hospice benefit with the new provider. If a patient is discharged from a hospice during a Medicare benefit period for any reason other than a transfer either they are no longer receiving Medicare coverage for hospice, Medicare coverage is resumed under CFR 418.24e, or they may reelect hospice care if eligible with a new benefit period

On transfers, agencies are required to have a statement that contains vital pieces of information:

1. The name of the hospice currently providing care (From)
2. The name of the hospice to assume care (To)
3. The date the transfer is to occur
4. Signatures of the recipient or representative

Recent changes from previous procedures

Formerly, billing through the Common Working File (CWF) was able to process claims that had had a different “to” and “from” date on transfers. This is no longer the practice. CMS will consider any gap, including one day, to be a discharge from one hospice and will require an admission to a new benefit period by the receiving hospice. Transfers that cause a break in service days may bring scrutiny from CMS as a violation of a live hospice care recipient (42 CFR 418.26a). The CWF will now reject transfers and billing that do not have the same “to” and “from” date.

Implications for hospice agencies involved with transfers are numerous. Where possible, orderly transfer should involve:

• Properly completed transfer form noting the “to” and “from” agencies
• History and Physical, visit notes, and Interdisciplinary Team records
• Previous Certifications of Terminal Illness (CTI) and Face-to-Face (F2F) Documents
• Durable Medical Equipment needs
• Medication and supply needs
• Necessary demographics

Considerations with transfers

Considerations should be made if a transfer can logistically be made from one agency to the next without a gap in care. Are they in the same geographic area? Is the patient moving a great distance or requiring extensive travel? Is weather a factor in the transfer that could delay a same day transfer? Examine all scenarios to ensure continued care meets requirements without the need for discharge and readmission.

Reasons for transfer can vary. A patient may require a specific service such as inpatient or specialty services, for which one hospice may not have a contractual arrangement. Perhaps an individual is relocating out of a defined service area. Patients may transfer to a non-contracted facility for residential care. The rationale may be as simple as a patient choosing a different service provider. Hospices should work collaboratively to ensure a smooth transition of care no matter the reason for transfer.

With no break in the care, all documents, not simply the current benefit period’s documentation, may be used. This may include the Election of Benefit (EOB), initial plan of care, comprehensive assessments, previous certifications and F2F documents. If utilized, the receiving program becomes responsible for the language and contents; therefore, a robust review for technical eligibility is imperative. Many receiving programs choose to enact their own consents, F2F and CTIs.

When transferring to another hospice, the claim does not change the dates of the benefit period. Rather, the admitting hospice submits a transfer notice. The former hospice will be responsible for finalizing their billing before a new billing cycle can be processed.  Billing procedures should follow CMS guidelines and ensure demographics, billing codes and provider codes are accurate to avoid rejection.  It is advisable to have direct contact between hospices to ensure both agencies are clear regarding the patient status of transfers versus discharge and readmission to avoid billing issues.