CMS is introducing new billing instructions when a hospice is involved in a patient transfer.
 
Currently, transfers are being allowed to process through the Common Working File (CWF) with a “from date” from the receiving hospice that doesn’t match the “to date” from the transferring hospice.
 
“We consider any gap, even of one day, to be a discharge and readmission rather than a transfer, and the beneficiary would have to re-elect hospice care with the new hospice,” according to CMS in MLN Matters 12619.
 
CMS is creating a new CWF edit that no longer allows gaps of care to occur during a transfer. “The CWF will reject the hospice transfer if the transfer doesn’t occur immediately and there’s a gap in the number of billing days between one hospice and the next,” according to CMS. If the receiving hospice’s claim “from date” is not the same as the transferring hospice’s “through date” with “patient status” indicating a transfer (codes 50 or 51), the transfer will be rejected.
 
This will require an important piece of documentation for both hospice providers, according to MM 12619:
 
To transfer hospice programs, the patient or representative must file, with the hospice from which care has been given and with the newly designated hospice, a statement that includes the following information:
  1. The name of the hospice from which the individual was given care and the name of the hospice from which he or she plans to get care.
  2. The date the change is to be effective.
The change is effective July 1, 2022, with an implementation date of July 5.