Electronic Submission of Hospice NOEs
Author: Elizabeth Wilson
On July 27, 2017, the Centers for Medicare & Medicaid Services (CMS) issued Change Request (CR) 10064, Accepting Hospice Notices of Election (NOE) via Electronic Data Interchange (EDI). This CR permits electronic filing of hospice NOEs through the EDI, effective for transactions beginning January 1, 2018. Attachment 1 to CR 10064 includes the NOE Companion Guide, which provides instructions for setting up the electronic NOE file.
When patients elect the Medicare hospice benefit, they must select a specific hospice agency for treatment concerning their terminal diagnosis. The hospice must then submit an electronic NOE billing transaction to its Medicare Administrative Contractor (MAC), which in turn establishes the hospice benefit period in the Medicare Common Working File. Beginning in October 2014, CMS began requiring hospices to submit NOEs within five days following a hospice admission. The purpose of this five-day requirement was to inform CMS and all other health care providers of the beneficiary’s hospice status as quickly as possible. This requirement also established a stiff financial penalty for submitting a late NOE with limited acceptable exceptions.
One of the challenges to submitting NOEs on time has been the inability to submit using EDI. Hospice providers have had to submit NOEs using the Direct Data Entry (DDE) system, which requires DDE users to hand-key the NOEs or use third-party software that relies on keyboard emulation to submit the NOE data into DDE. This process has been prone to human error, often resulting in lost revenues.
Preparation for Electronic NOE Submissions
With the implementation of CR 10064, hospices may continue to manually submit NOEs using DDE or keyboard emulation, as that process won’t change. However, they also will be able to electronically submit NOEs in the 837I transaction claim format. Since all information needed for an NOE should be included in the electronic medical record or software system used by the hospice, that data may be formatted into an 837I transaction and electronically submitted through EDI with less risk of human error related to data entry.
As hospices work with software vendors to prepare their systems for the new 837I transaction claim format, it’s important to consider the following:
- NOEs aren’t claims and don’t require the same fields to be populated as hospice claims. Therefore, hospice IT departments or software vendors will need to use the NOE Companion Guide, which outlines how to complete the data elements required in the 837I format, but not required for an NOE. All required fields will need to be populated with “filler” data in the NOE 837I transaction file and electronically submitted through EDI to the MAC. Upon receipt, the MAC will then remove all information found in the 837I that’s not required for an NOE prior to placing it into the Fiscal Intermediary Standard System (FISS) for processing.
- Many hospice software systems are set to generate hospice electronic 837I claim submissions on a monthly basis, upon discharge or in batches. Since NOEs are highly time-sensitive, the software will need to allow for daily or on-demand processing for these transaction files based on hospice admission timing.
The data entered into your electronic medical record or software system must be accurate to realize the benefits of submitting NOEs through EDI. This process eliminates the keying errors that can occur by manually entering NOEs using DDE, but the electronic submission only is as error-free as the original data. Hospice intake, clerical and clinical staff will need to be diligent concerning the creation of records and the entering of data for their admissions. Once an NOE is created, there should be formal processes to ensure the data is compliant before submission. Ideally, hospice providers can work with their software vendors to use electronic edits to help reduce errors prior to NOE submission. Once submitted, hospices will need to validate that the MAC accepted the NOEs. Finally, hospices will need to continue monitoring FISS to verify NOEs are processing and ultimately move into a paid status.
For additional information, refer to the CMS website or contact your trusted BKD advisor.