Accurate hospice billing is essential for maintaining Medicare compliance and ensuring claims are processed correctly. Medicare has identified an increase in claim errors during Medical Review because many hospices are not reporting post-mortem visits with the required PM modifier. These reporting mistakes can lead to review findings and may also affect the proper calculation of Service Intensity Add-On (SIA) payments.
Medicare Requirement for Reporting Post-Mortem Visits
Hospices are required to report post-mortem visits performed by hospice-employed professionals, including:
- Nurses
- Hospice aides
- Social workers
- Therapists
Any visit that takes place after the patient’s death on the official date of death must be billed using the PM modifier. This requirement applies regardless of the patient’s level of hospice care or the location where services were provided.
Hospices should not report post-mortem visits that occur on any day after the patient’s recorded date of death.
Understanding the Official Date of Death
For Medicare billing purposes, the patient’s date of death is the date listed on the official death certificate.
If a hospice staff member provides care both before and after the patient’s death on the same day, those services must be reported separately on the claim. Pre-death services and post-mortem services cannot be combined on a single billing line.
Example: Visit Before and After the Patient’s Death
Consider a situation where a hospice nurse arrives at the patient’s home at 9:00 p.m. to provide Routine Home Care (RHC). The patient passes away at 11:00 p.m., and the nurse remains with the family until 1:30 a.m.
In this case:
- The visit provided from 9:00 p.m. to 11:00 p.m. should be billed as a standard nursing visit with eight 15-minute units.
- The time spent after the patient’s death, from 11:00 p.m. to midnight, should be reported on a separate claim line using the PM modifier with four 15-minute units representing the one-hour post-mortem visit.
Example: Nurse Arrives After the Patient Has Passed Away
In another scenario, suppose the patient dies unexpectedly at 11:00 p.m., and the hospice nurse reaches the home after the death has occurred. The nurse stays with the family until 1:30 a.m.
For billing purposes, the hospice should submit a separate nursing visit line using the PM modifier and report four 15-minute units to reflect the one-hour post-mortem visit provided between 11:00 p.m. and midnight.
Why Correct PM Modifier Reporting Matters
Using the PM modifier correctly helps ensure:
- Compliance with Medicare billing requirements.
- Accurate processing of hospice claims.
- Proper calculation of Service Intensity Add-On (SIA) payments.
- Reduced risk of Medical Review findings and billing errors.
- Cleaner claims with fewer delays or payment adjustments.
Hospice providers should review their billing procedures and educate clinical and billing staff to ensure post-mortem visits are documented and reported according to Medicare guidelines.
Resource: Medicare Claims Processing Manual, Chapter 11 — Processing Hospice Claims (PDF), section 30.3 — Data Required on the Institutional Claim to A/B MAC (HHH).