As previously reported, in July 2022 a claims processing edit to prevent gap billing between hospice transfers will be implemented. A gap is most likely to occur in situations where a patient requests to transfer to a hospice that is outside of the geographic service area and requires some time of travel.
The Centers for Medicare & Medicaid Services (CMS) recently updated Change Request (CR) 12619 Gap Billing Between Hospice Transfers which provides instructions to the Medicare Administrative Contractors (MACs) to implement the edit and updates Chapter 11 of the Medicare Claims Processing Manual to reflect that there must not be a gap in billing for hospice transfer situations, a hospice transfer will be rejected if the transfer does not occur immediately. The Manual instructions indicate that transfers are not allowed from the same provider.
Hospices must not submit an 8XC if the CMS Certification Number (CCN) is the same. In this scenario the beneficiary is not transferred to another hospice, they are transferred to another location of the same hospice. It is the term “another location” that is new in this revised CR.
Originally, the term “subunit” was used which is a specified term associated with home health agencies. The use of the term could be confusing to hospices as they do not have “subunits” so it was replaced with “another location.”