Medicare Administrative Contractors (MACs) continue to receive inquiries and disputes regarding hospice providers that fail to report live discharges or revocations in a timely manner when a beneficiary’s Medicare Hospice Benefit election ends. Delayed reporting can create challenges for beneficiaries seeking other medical services, affect reimbursement for other healthcare providers, and lead to payment penalties related to late Notices of Election (NOEs) when beneficiaries reelect hospice care.
When a hospice beneficiary is discharged alive or chooses to revoke hospice care, the hospice provider must submit a timely Notice of Election Termination/Revocation (NOTR) using bill type 8xB, unless a final claim has already been filed. To be considered timely, the NOTR or final claim must be submitted to and accepted by the hospice MAC within five calendar days of the effective discharge or revocation date.
Failure to report a discharge or revocation within the required timeframe can result in compliance issues, delayed processing, and disputes between hospice providers if the beneficiary later reelects hospice services. If a beneficiary reenrolls with the same hospice and the previous live discharge was not reported on time, the hospice may face payment reductions due to a late NOE submission. In addition, hospice claims must be processed in chronological order, meaning that a discharge or revocation must be reported before a new NOE can be submitted for a subsequent election period.
It is important to note that changing from one hospice provider to another is considered a transfer, not a revocation or termination of the Medicare Hospice Benefit election. Therefore, when a beneficiary transfers to a different designated hospice, a revocation or discharge of the hospice benefit should not be submitted.
Resource: Medicare Benefit Policy Manual Chapter 9 – Coverage of Hospice Services Under Hospital Insurance