Last Friday CMS re-issued Change Request (CR) 8358– Additional Data Reporting Requirements for Hospice Claims in order to clarify the reporting requirements and make technical corrections. None of the requirements in the original CR have changed including the mandatory reporting implementation date of all claims with dates of service on or after April 1, 2014.
CR 8358 revises Section 30.3 of Chapter 11 of the Medicare Claims Processing Manualand requires the following additional data required on hospice claims includes:
- General inpatient (GIP) visit reporting for certain hospice-paid staff (in 15-minute increments)
- Facility National Provider Identifier (NPI) number when care provided is not at the hospice facility that is billing the care
- Post mortem (PM) visit reporting
- Injectable drugs
- Non-injectable prescription drugs
- Infusion pumps
After the CR was originally issued in July 2013, the hospice providers and hospice stakeholders had numerous questions about the details of the requirements especially the bullet points pertaining to the reporting of drugs and infusion pumps. After doing some research into billing Medicare for medications it became clear that hospices needed several pieces of information in order to submit a compliant claim. Not all of this information was specified in the CR because it is elsewhere in the Claims Processing Manual and part of HIPAA v5010 requirements. For instance, billing of any prescription medication requires an NDC number and a corresponding charge. The NDC number detail and charge detail are part of already existing billing requirements and were not separately specified in the CR.
Below is a summary of the recent clarifications for CR 8358. In addition to these clarifications, NAHC has developed a list of the Q&A’s related to CR 8358.
This list is compiled from hospice provider and hospice stakeholder input and is available here.
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Reporting Requirement |
Clarification |
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Line-item visit data for hospice staff providing inpatient care (GIP) to hospice patients in skilled nursing facilities or hospitals |
Clarification that this change imposes the same line item requirements as currently applied under routine home care and continuous home care (previous CR language referred to “the home levels of care”). NEW LANGUAGE: This includes visits by hospice nurses, aides, social workers, physical therapists, occupational therapists, and speech-language pathologists, on a line-item basis, with visit and visit length reported as is done for routine home care and continuous home care. |
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Reporting of injectable and non-injectable prescription drugs |
Clarification on reporting, including specifying that if a facility uses a medication management system where each administration of a hospice medication is considered a fill, those drugs should be reported on a monthly basis per drug. The additional information also provides greater clarity relative to reporting on compounded drugs, comfort kit/pack, and infusion pumps. NEW LANGUAGE: Hospice agencies shall report injectable and non-injectable prescription drugs for the palliation and management of the terminal illness and related conditions on their claims. Both injectable and non-injectable prescription drugs shall be reported on claims on a line-item basis per fill, based on the amount dispensed by the pharmacy. When a facility (hospital, SNF, NF, or hospice inpatient facility) uses a medication management system where each administration of a hospice medication is considered a fill for hospice patients receiving care, the hospice shall report a monthly total for each drug (i.e., report a total for the period covered by the claim), along with the total dispensed. Hospices shall report multi-ingredient compound prescription drugs (non-injectable) using revenue code 0250. The hospice shall specify the same prescription number for each ingredient of a compound drug according to the 837i guidelines in loop 2410. In addition, the hospice shall provide the NDC for each ingredient in the compound; the NDC qualifier represents the quantity of the drug filled (meaning the amount dispensed) and shall be reported as the unit measure. When reporting prescription drugs in a comfort kit/pack, the hospice shall report the NDC of each prescription drug within the package, in accordance with the procedures for non-injectable prescriptions. Hospice agencies shall report infusion pumps (a type of DME) on a line-item basis for each pump and for each medication fill and refill. The hospice claim shall reflect the total charge for the infusion pump for the period covered by the claim, whether the hospice is billed for it daily, weekly, biweekly, with each medication refill, or in some other fashion. The hospice shall include on the claim the infusion pump charges on whatever basis is easiest for its billing systems, so long as in total, the claim reflects the charges for the pump for the time period of that claim. |
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Reporting of Post Mortem Visits |
Clarifies date of death and that “visits” prior to death are reported on a separate line from those occurring after death. The document also provides an example. NEW LANGUAGE: PM – Post-mortem visits. Hospices shall report visits and length of visits (rounded to the nearest 15 minute increment), for nurses, aides, social workers, and therapists who are employed by the hospice, that occur on the date of death, after the patient has passed away. Post mortem visits occurring on a date subsequent to the date of death shall not be reported. The reporting of post-mortem visits, on the date of death, shall occur regardless of the patient’s level of care or site of service. Date of death is defined as the date of death reported on the death certificate. Hospices shall report hospice visits that occur before death on a separate line from those which occur after death. For example, assume that a nurse arrives at the home at 9 pm to provide routine home care (RHC) to a dying patient, and that the patient passes away at 11 pm. The nurse stays with the family until 1:30 am. The hospice should report a nursing visit with eight 15-minute time units for the visit from 9 pm to 11 pm. On a separate line, the hospice should report a nursing visit with a PM modifier with four 15-minute time units for the portion of the visit from 11 pm to midnight to account for the 1 hour post mortem visit. If the patient passes away suddenly, and the hospice nurse does not arrive until after his death at 11:00 pm, and remains with the family until 1:30 am, then the hospice should report a line item nursing visit with a PM modifier and four 15-minute increments of time as the units to account for the 1 hour post mortem visit from 11:00 pm to midnight. |
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Reporting of the NPI where the patient is receiving hospice services when the site of service is not the billing hospice |
Technical correction regarding the version of the electronic claim record NEW LANGUAGE: The billing hospice shall obtain the NPI for the facility where the patient is receiving care and reporting the facility’s name, address and NPI on the 837I electronic claim format in loop 2310 E Service Facility Location. |