On August 31, 2016, NHPCO staff and provider representatives from NHPCO’s NOE/NOTR Workgroup, met with individuals from CMS’ Provider Billing Group and Chronic Care Policy Group to share concerns about the NOE/NOTR process.
Provider representatives from Hospice of Michigan and Seasons’ Hospice and Palliative Care shared first-hand, on the ground examples of the financial and administrative burdens they’ve faced with the NOE/NOTR and sequential billing processes.
CMS staff were receptive to NHPCO's concerns, especially with regard to NOEs that should fall within the existing exception categories as well as inconsistencies with NOE filings across and within the various MACs. CMS also stated that they do not hear much from the field (either providers or MACs) that this issue is a significant problem, nor do they hear concerns about the loss of provider revenue.
CMS continues to work on a new system function to submit NOEs electronically, and to revamping the FISS system for hospice data. They predicted that the electronic submission fix is at least one year away, but is in development at this time. A more complete revamp is a longer term goal.
NHPCO members will hear more about this issue as it moves forward; members will find the latest regulatory and compliance news in the Regulatory & Compliance Center on NHPCO's website.