Hospice Questions Remain as ICD-10 Transition Looms

With the transition to the impending ICD-10 code set slated to begin next week, hospice providers still face some substantial questions regarding their ability to smoothly implement the new system, according to the National Association for Home Care and Hospice (NAHC).

NAHC has been in touch with the Centers for Medicare & Medicaid Services (CMS) about discrepancies in diagnoses codes on hospice claims, according to the association. Specifically, NAHC has asked whether a principal diagnosis code is required on Notices of Termination/Revocation (NOTR) forms, which must be submitted within five calendar days of starting care.

About 69,000 new medical codes officially go into effect Oct. 1, replacing the approximately 14,000 codes currently available with ICD-9. The adoption of the new code set is meant as a way for providers to keep up with advancements in medicine and the health care system’s growing data demands.


NAHC noted that some Medicare Administrative Contractors are processing NOTRs without a principal diagnosis code, although CMS rules indicate such a code is in fact required. Clarification from CMS on the issue is forthcoming, according to the NAHC news release.

Meanwhile, Notices of Election (NOEs) always call for a principal diagnosis code, and those filed with improper codes on or after Oct. 1 will be returned to the provider and could result in loss of some days of payment for the hospice, the release states. The same holds true for NOTRs submitted with ICD-9 codes following the transition. Reduced cash flow has been a major concern for home health and hospice agencies as ICD-10 implementation looms.

In addition to confusion surrounding principal diagnosis code requirements under ICD-10, there are several diagnosis codes that cannot be included as the principal diagnosis on hospice claims, the release states. Certain manifestation codes in ICD-10 cannot be used as the principal diagnosis code, either, according to the release. Several such codes have been added to the list of those considered unacceptable effective Oct. 1.


Written by Kourtney Liepelt

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