Hospice Transfer Requirements

The admission process is one of the most important steps in Hospice Billing. Upon admission, providers are required to verify the beneficiary’s eligibility files to ensure the beneficiary is entitled to Medicare and determine if prior hospice benefit periods exist.

An individual may change, once in each benefit period the designation of the particular hospice from which he or she elects to receive hospice care. The change of the designated hospice is not a revocation of the election, but is a transfer, and it must occur on the same date. When a beneficiary was discharged or revoked from the Medicare Hospice Benefit, readmission cannot occur on the same day. It is imperative that hospices work together when a beneficiary chooses to change hospices.

Transfers are not allowed from the same CMS Certification Number (CCN). Hospices must not send an 8XC if the CCN is the same for the transferring and receiving hospice. In this case, the beneficiary is not transferred to another hospice, they are transferred to another location of the same hospice.

To ensure proper billing and avoid overlapping situations where a transfer takes place, hospices should view the beneficiary’s eligibility records in Palmetto GBA's eServices online provider portal via the Eligibility tab or any HIPAA (Health Insurance Portability and Accountability Act) Eligibility Transaction System (HETS) based system. To access the beneficiary’s eligibility records in eServices:

• After signing into the system, select the Eligibility tab, and enter the beneficiary’s first and last name, Medicare Beneficiary Identifier (MBI), date of birth and a date range
  • To retrieve all information available, you must enter a valid date range. The HETS 270/271 system allows date requests up to four (4) years prior to, and four (4) months in the future of, the NOTE current date. Date ranges may not exceed 24 months at a time.

  Situation

  Yes

  No

  Action

  Prior hospice benefit period(s) found?

  Verify the revocation indicator and make note of the CCN or NPI of any other hospices found. You may use the National Plan & Provider Enumeration System (NPPES) website to look up the other hospice’s contact information using the NPI.

  Ask the beneficiary or authorized representative if hospice care has been provided at any time in the past. If not, then proceed with the admissions process.

  Prior benefit period(s) found, and revocation indicator is 1 or 2?

  This indicates that the beneficiary has been discharged or revoked from the Medicare Hospice Benefit. Proceed with normal admission process.

  Note: Be sure to verify the end date of the existing benefit period. A new benefit period cannot begin on the same date as the end date of an existing benefit period.

  Verify that a transfer has not already taken place within the existing benefit period.

  Beneficiary-elected transfer has already taken place between two hospices during the election/benefit period?

  Inform the beneficiary that he or she is not eligible to transfer to another hospice until the beginning of the next election/benefit period.

  Proceed with the transfer process.

  Transfer Requirements

  Either the transferring/discharging or receiving hospice may assist the beneficiary/authorized representative with initiating the transfer. In either case, the following requirements must be met:

  1. Contact must be made with the other hospice and the following must be documented:
  • The method of the communication (e.g., email, telephone, fax)
  • Date/time of the contact with the other hospice
  • The name individual with whom you communicated at the hospice
    • Note: Unanswered communications are not acceptable. Ensure that you document the response from the other hospice to ensure both hospices are in agreement with the terms of the transfer.
    1. The transfer date must be agreed upon before the transfer takes place. The transfer date must be the same date the beneficiary leaves one hospice and received by the other hospice.
    • There cannot be a gap in days. When one hospice transfers a beneficiary to another hospice with any gap following the date of transfer, this is deemed a gap in care and therefore, would not be considered a continuous hospice election. CMS considers 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
    1. Explain to the beneficiary or the authorized representative that he or she is required to sign and date the transfer agreement form (hospices have the flexibility to design and create their own forms, but only one form is required). The transfer form must also include the following:
    • The name of the hospice from which the individual has received care;
    • The name of the hospice from which they plan to receive care; and
    • The date the change is to be effective
    1. Ensure that a copy of the transfer agreement form is on file with both hospices before the transfer takes place.

    Steps for the Receiving Hospice

    1. Document in the record that you accessed the beneficiary’s eligibility records in the Hospice/Home Health screen in eServices or other HETS system.
    2. Contact the existing hospice to work out the transfer date if you are assisting the beneficiary/authorized representative with initiating the transfer.
    3. Complete all assessments required by the hospice conditions of participation as described in the Code of Federal Regulations, 42 CFR, PART 418, section 418.30.
    4. If the beneficiary is transferring hospices in the third or later benefit period, a face-to-face encounter is not required if the receiving hospice can verify that the originating hospice had the encounter.
    5. A change of ownership of a hospice is not considered a change in the beneficiary’s designation of a hospice and requires no action on the beneficiary’s part. See the Hospice Change of Ownership (PDF) job aid and the Hospice Notice of Change of Ownership 8XE (PDF) job aid for more information.
    6. Ensure that all transfer requirements listed above have been met.
    7. Ensure that the transferring/discharging hospice has already submitted their final claim (8X1 or 8X4), and then submit the Notice of Change (8XC) (PDF) to Medicare.
    8. After the Notice of Change (8XC) is processed, subsequent claims may then be submitted.

    Steps for the Transferring/Discharging Hospice

    1. Contact the receiving hospice if you are assisting the beneficiary/authorized representative with initiating the transfer, and document the information outlined above in the transfer requirements section.
    2. Submit your final claim with Patient Status Code 50 or 51 to indicate transfer to another hospice.
    • If a gap in care occurs (receiving hospice does admit the beneficiary on the transfer date), the transferring hospice needs to submit their final claim with an appropriate discharge Patient Status Code, other than 50 or 51
    • No additional discharge codes are required
    • Document gap occurrence in discharge summary
    1. Ensure the dates of service on the claim are correct and align with the transfer date.
    • Beneficiary elects to transfer on 08/05
    • The transferring/discharging hospice submits their final claim (8X4) with dates of service 08/01 through 08/05 and a Patient Status Code of 50 or 51
    • Receiving hospice submits their Notice of Change (8XC) with 08/05 as their "Admit" and "From" date. The date reported with occurrence code 27 is the start date of the benefit period in which the beneficiary transferred.
      • Once the 8XC is processed, the claim for dates of service 08/05 to 08/31 (assuming the beneficiary is still on service at the end of the month) may be submitted

      Geographical Location Transfers

      If the beneficiary is transferring from outside the service area and the transferring hospice can’t arrange care until the beneficiary reaches the new hospice, the hospice may discharge the beneficiary. This way, if the beneficiary requires medical treatment while in the process of transferring, he or she can access it under his or her Original Medicare coverage. This would end the beneficiary’s current benefit period and require the beneficiary to re-elect hospice coverage at the new hospice and begin a new benefit period.

      If a discharge does not occur when beneficiaries or authorized representatives choose to change hospices from one geographical location to another, hospices often question payment responsibility for certain services that may be needed during the time the beneficiary is traveling from one area to another. Before the change of hospice takes place, both hospices should:

      1. Work together to determine payment responsibility if ambulance transport is needed.
      2. Assess the following:

      Situation

      Yes

      No

      Action

      Determine the length of time it will take for the beneficiary to travel from one location to another. Is the length of time short enough in duration such that one or both hospices could provide care if necessary?

      Both hospices should coordinate with each other to determine which hospice will provide any care that may be necessary.

      Determining whether or not the beneficiary will be traveling through a geographical location in which one or both hospices is authorized to provide care if necessary. If not, then the beneficiary may need to be discharged from the existing hospice and readmitted by the receiving hospice on a later date.

      Will the beneficiary be traveling through any geographical location in which one or both hospices have the authority to provide care if necessary?

      Both hospices should coordinate with each other to determine which hospice will provide any care that is necessary.

      Determine if the beneficiary will be traveling through a geographical area in which neither hospice has the authority to provide care. If not, then the beneficiary may need to be discharged from the existing hospice and readmitted by the receiving hospice on a later date.

      Will the beneficiary potentially need care in a geographical location in which neither hospice as the authority to provide care?

      The beneficiary may need to be discharged from the Medicare Hospice Benefit and the readmitted by the receiving hospice on a later date after arriving at his/her destination. The readmission cannot occur any earlier than the day after the beneficiary was discharged from the last hospice election.

      If so, then the beneficiary may need to be discharged from the existing hospice and readmitted by the receiving hospice on a later date.

      References

      • Internet-Only Manual (IOM), Publication 100-02, Chapter 9 (PDF), Section 20.2.1
      • Internet-Only Manual (IOM), Publication 100-04, Chapter 11 (PDF), Sections 20.1.2, 30.3 and 90
      • MLN Matters Number: MM12619 (PDF) — Gap Billing Between Hospice Transfers
      • eServices Portal
      • HIPAA Eligibility Transaction System (HETS)

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