CMS Simplifies Hospice Vaccine Billing Effective October 2016
Change Sought by NAHC, Forum of State Associations
May 1, 2016 11:40 AM
The Centers for Medicare & Medicaid Services (CMS) has just issued Change Request 9052/Transmittal 3503 which, effective October 1, 2016, allows hospices to bill Medicare for covered preventive vaccines (influenza virus, pneumococcal, and hepatitis B) directly on the institutional claim rather than requiring that they secure and maintain separate enrollment and bill vaccines as a Medicare Part B Supplier in order to receive payment. CMS references this change as providing “administrative simplification for both hospices and Medicare. If the services are billable on institutional claims, hospices will not need to maintain separate billing systems to create professional claim formats for vaccine services or to submit paper CMS-1500 claim forms for these services. The Medicare program will reduce the number of enrollments it must process and maintain. It will also reduce claims processing workloads for paper claim submissions.”
This change, along with clarifications on CMS policy related to coverage of preventive vaccines for hospice patients, was sought by the National Association for Home Care & Hospice (NAHC) and its affiliated Forum of State Associations (FSA) during 2013 (see previous NAHC Report coverage here and here). While CMS alerted NAHC some time ago that it planned to make these changes, implementation was delayed due to the significant number of other systems changes that were scheduled for implementation.
With issuance of the change, CMS institutes a policy for hospice billing of preventive vaccines that is comparable to what is applicable for home health providers, except that home health agencies are paid at the outpatient prospective payment rate and hospices will be paid based on the Medicare Physician Fee Schedule (MPFS). In its manual updates connected to CR9052, CMS underscores that preventive vaccines are not part of the hospice benefit and must be billed on a separate claim that includes only the vaccines and their administration. The manual changes also indicate that while any hospice currently billing preventive vaccines as a supplier may change its processes so as to bill vaccines on the institutional claim, a hospice enrolled as a supplier under Part B may also continue to bill vaccines through Part B if it wishes to.
As part of CR9052, CMS also includes the following new language in Chapter 18 (Preventive and Screening Services) of the Medicare Claims Processing Manual under section 10.2.3:
The following provides billing instructions for hospices:
Hospices can provide the influenza virus, pneumococcal, and hepatitis B vaccines to those beneficiaries who request them including those who have elected the hospice benefit. These services may be covered when furnished by the hospice.
For dates of service before October 1, 2016, services for vaccines and their administration provided by a hospice should be billed on a professional claim to the local MAC. Payment is made using the same methodology as if they were a supplier. Hospices that do not have a supplier number should contact their MAC to obtain one in order to bill for these benefits.
For dates of service on or after October 1, 2016, services for vaccines and their administration provided by a hospice may be billed on an institutional claim.
Following is a link to a CMS document regarding Medicare Part B Immunization Billing containing applicable procedure codes and descriptors, as well as additional information related to institutional billers. This document has not yet been updated to include the hospice types of bills (081x or 082x) in the list of Facility Types and Types of Bills on page 4.
NAHC reminds hospice providers that currently bill for preventive vaccines as suppliers that this change will not be effective until October 1, 2016, so hospices currently enrolled as suppliers may wish to maintain that enrollment at least until that time. As additional information about this change becomes available, it will be published in NAHC Report.