The Centers for Medicare & Medicaid Services’ (CMS) Medicare Claims Processing Manual, Chapter 11, Section 20.1.2, has long contained policy requiring hospices to include a principal diagnosis when submitting Notice of Election (NOE) billing transactions. Previously, there wasn’t an edit in place to enforce this requirement—but that has now changed.
On October 3, 2016, CMS issued Change Request (CR) 9575, which implemented an edit within the Fiscal Intermediary Shared System requiring NOEs to be submitted with a principal diagnosis code. The edit is effective for dates of service January 1, 2016, and forward and indicates NOEs submitted without a principal diagnosis code will be returned for correction. The principal diagnosis code indicated on the NOE is the code that best represents the patient’s terminal prognosis at the time of patient admission.
It is critical that hospices correctly indicate the principal diagnosis code on NOEs. This helps avoid the risk of lost payments due to NOEs being accepted by the Medicare Administrative Contractors outside of the required five-day window that begins with the date of hospice admission.
Additional information concerning CR 9575 can be found here.
Contact your BKD advisor if you have questions.