CMS Adds Hospice NOE Edit for Principal Dx to FISS
May 4, 2016 10:53 AM
Since implementation of the timely filing requirements for Notices of Election (NOE) and Notices of Termination/Revocation (NOTR), the Centers for Medicare & Medicaid Services (CMS) has been working to address issues associated with the requirements. Most recently, CMS issued Change Request 9575/Transmittal 3502, which instructs the Medicare Administrative Contractors (MACs) to implement an edit within the Fiscal Intermediary Shared System (FISS) for hospice NOEs submitted without a principal diagnosis listed. The CR is effective for claims with dates of service on or after January 1, 2016 but has an implementation date of October 3, 2016. Once this edit is implemented, hospices will be alerted immediately when trying to submit an NOE that does not contain a principal diagnosis so that the NOE may be corrected prior to submission.
It is longstanding policy within the Medicare Claims Processing Manual, Chapter 11, Section 20.1.2 that hospices must include a principal diagnosis on the NOE but there has not been an edit to prevent NOEs from processing without a principal diagnosis. This will change with CR9575.
In related news, hospices are reminded that at this time there is not an edit comparing the principal diagnosis on the NOE with the principal diagnosis on any corresponding claim(s). CMS expects that if there is a change in diagnosis from admission, the medical record will contain documentation explaining this. There are times when the diagnosis listed on the NOE changes, sometimes soon after the NOE is submitted. This change is not considered an error. An error would be when the hospice has entered a principal diagnosis on the NOE that is different than what the physician determined to be the principal diagnosis at the time the NOE was submitted. If the physician changes the principal diagnosis after the NOE is submitted (i.e. after obtaining more data/information from the inter-disciplinary team, attending physician’s office, discharging facility, etc.), but the diagnosis on the NOE was correct on the day the NOE was submitted, this is considered a change rather than an error. A change does not require the NOE to be corrected. An error does require correction and often results in loss of days of revenue due to a late NOE.