Hospice NOE/NOTR Update
October 18, 2016 03:52 PM
Based on hospice provider feedback, the National Association for Home Care & Hospice (NAHC) understands that problems associated with timely submission/acceptance of hospice Notices of Election (NOE), as well as Notices of Termination and Revocation (NOTR), continue to have a substantial negative impact on hospice revenues and operations. The Centers for Medicare & Medicaid Services (CMS) is engaged in ongoing efforts to address these concerns (see previous NAHC Report coverage: http://www.nahc.org/NAHCReport/nr160809_1/, http://www.nahc.org/NAHCReport/nr160808_1/, http://www.nahc.org/NAHCReport/nr160606_1/, http://www.nahc.org/NAHCReport/nr160503_1/).
NAHC is providing the following update on progress in this area, based on recent discussion with CMS staff. CMS’ current plan to mitigate existing problems with NOE submission and acceptance by the Medicare Administrative Contractors (MACs) involves three separate efforts:
(1) Redesign of the Common Working File (CWF) in order to have benefit period information separate from election information independent of claims processing to allow for greater functionality,
(2) Modification of the 837i (institutional electronic claim) transaction to allow for electronic submission of the NOE, and
(3) Significant revamping of information included in the Medicare Claims Processing Manual related to NOE, NOTR, and CHOW.
Following is more detail related to these efforts, as well as the anticipated time frames for completion, where applicable:
Redesign of the Hospice Benefit Period Information in the CWF: The current structure of the CWF does not allow for separate access to sufficient detail on hospice elections and benefit period information that is independent of claims processing. CMS plans to separate election information from benefit period information in the CWF, which will allow for greater functionality and flexibility in the processing of election information and thereby reduce administrative burdens on providers and the MACs. It is anticipated that this change will permit changes to alleviate a number of the issues associated with direct data entry and processing of NOEs. CMS and the MACs conducted an analysis earlier this year and plans are now in place to make the necessary changes. However, the changes are so significant that they must be approached carefully, and require four separate updates via the routine quarterly releases of updates to the CMS software systems. At this time CMS plans to issue the first of the four releases in April 2017, which means that if there are no unanticipated issues that arise while the changes are implemented and none of the releases is delayed, the work could be completed by January 2018.
Electronic Submission of NOE: While CMS initially believed it could not permit hospices to submit NOEs electronically, analysis conducted by NAHC and submitted earlier this year (http://www.nahc.org/NAHCReport/nr160606_1/) convinced CMS that its previous understanding was incorrect. CMS sought and received internal clearance to pursue electronic processing and solicited further input from an external electronic standards-setting body - The Accredited Standards Committee’s X12. CMS is in the process of addressing the recommendations laid out by X12. CMS may not require hospices to submit the NOE/NOTR electronically – this must be a voluntary action because of current federal rule. Electronic submission of the NOE/NOTR means that hospices would be notified during the NOE/NOTR submission process of errors such as incorrect beneficiary information. Hospices would still have problems if the election date is entered incorrectly, but most other issues would be identified upfront, which would eliminate the days of processing currently needed to identify these types of errors. CMS will need to develop a companion guide for 837i that hospice providers planning to submit NOE/NOTR electronically must agree to follow. If this process continues to move forward as anticipated, hospices may be permitted to submit NOE/NOTR using the 837i by late 2017. Again, issues could arise at any point in the process, but a great deal of progress has been made to date.
Revamping of Claims Processing Manual: Through the process of addressing problems associated with timely filing of NOE/NOTR, CMS has concluded that there appears to be no single resource that providers can turn to for comprehensive information on submission of NOE/NOTR. For this reason, it plans to revamp the Claims Processing Manual to provide more comprehensive information related to NOE, NOTR, and CHOWs. Given CMS’ ongoing and intensive work related to the two issues above (CWF redesign and electronic submission of NOE) and other important matters, claims processing staff have not yet been able to invest significant effort in this project so an estimated time frame for completion of this task is not yet available.
NAHC will continue to monitor progress in these areas – please watch for updates on the NAHC member listserv and in future issues of NAHC Report.