CMS Updates the Exception for Untimely NOEs
Posted on Thursday, December 8, 2016 6:58 PM
The Centers for Medicare & Medicaid Services (CMS) updated the new exception for timely filing requirements, which will go into effect for claims submitted on or after November 16, 2016.
In accordance with the Change Request (CR) 8877, hospices are now required to submit a Notice of Election (NOE) for hospice patients admitted on or after October 1, 2014 within five days following the date of admission.
Since October 2014, several hospices have not met the NOE timely filing requirement due to submitting NOEs that have errors.
In February 2015, the Centers for Medicare & Medicaid Services (CMS) and the MACs confirmed when hospices discover they’ve submitted a NOE with a systems-detectable billing error that will cause the NOE to RTP, they could immediately submit a corrected NOE instead of waiting for the RTP to process.
The following examples are some common NOE and/or NOTR billing errors that could cause the submission to RTP:
• Invalid marital status
• Invalid/missing FROM date
• Invalid HICN
• Invalid/missing payer code
• Occurrence code 27 required on NOEs
• Invalid NPI – hospice agency or attending/certifying physician
• Invalid type of bill – inconsistent with provider number
• Beneficiary’s name/HIC don’t match
• NOE falls within established hospice benefit periods
Additionally, CMS has issued notice (MLN Matters Number SE1633: Exceptions for Late Hospice Notices of Election Delayed by Medicare Systems), where the MACs have authority to grant an exception to the five-day timely filing requirement for late NOEs when the NOE contains an error that cannot be corrected while the NOE is in process.
CMS has informed the MACs to grant an exception to the timely filing requirements in the following instances where hospices are unable to provide the MAC documentation showing:
1. When the original NOE was submitted
2. When the NOE was returned to the hospice for correction or was accepted and available for correction, and
3. When the hospice resubmitted the NOE.
CMS notes “If the hospice provides sufficient information in the Remarks section of its claim to allow the MAC to research the case, then MACs will make a determination without requesting the additional supporting documentation described above.”
CMS will continue to work on additional changes related to the timely filing requirements. Click here for an update.
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