2021 was an interesting year for many hospices as they navigated the intricacies of billing hospice care to Medicare Managed care plans as part of the VBID pilot. Mastering the maze of participating plans, NOE requirements, claim submissions, all while continuing to bill Medicare, was challenging, and Advanced Revenue Cycle Management was with our clients every step of the way. It took the better part of 2021 for many hospices to develop successful NOE and billing processes for those plans that initially didn’t have a clear set of instructions for us.
For VBID seasoned providers, heading into 2022 will be more of the same with many new participating Medicare Advantage plans in new geographic areas, but what we learned in 2021 will serve us well as we apply that knowledge to new plans. For hospice providers encountering VBID hospice coverage and billing for the first time in 2022, the prospect may appear daunting.
Advanced Revenue Cycle Management wants to share what we learned in 2021, so you don’t have to reinvent the wheel of VBID billing.
First! Review the CMS release of 2022 participating plans and expanded geographic areas to determine if your hospice is in a participating area.
Here are the top five steps all hospices in 2022 VBID expansion areas should implement:
- Reach out to the plans covering your area NOW. If you are unable to locate NOE and billing instructions on the plan’s website, the plan representative contact list is available from CMS.
- Ask for written hospice NOE submission instructions and obtain portal or website access if the plan accepts NOEs online. If you use a clearinghouse for electronic claims submissions, ask for external payer IDs for each plan so claims reach the correct processing location.
- Review your Medicare eligibility verification procedure with all pertinent staff. Upon eligibility verification for all 2022 admissions, make certain staff can identify the MA plan contract ID as well as the plan ID (three-digit extension) and cross reference the participating plan ID list to determine if the patient is covered by a VBID plan. REMEMBER- readmissions in 2022 may be covered by VBID MA plans where their prior admissions were covered by traditional Medicare!
- Develop a procedure to ensure all billing requirements are met for VBID plans. NOEs and claims must go to both Medicare and the participating plan, meeting all timely filing requirements- NOEs must be successfully submitted to both Medicare and the MA plan within the five-calendar day timely filing window.
- Work with your EMR now to determine how their system handles VBID billing. Your team must know how to enter all information correctly so elections and claims flow to both Medicare and the MA plan.
Patients covered by traditional Medicare in 2021 will continue to be covered by traditional Medicare in 2022 even if they have elected an MA plan that is participating in the VBID pilot in 2022, AS LONG AS THERE IS NO BREAK IN THE MEDICARE HOSPICE ELECTION. If patients with participating VBID MA plans terminate their Medicare hospice benefit on or after 1/1/2022 and re-elect hospice, the new election will be covered by the VBID MA plan. Do not assume prior patients are covered by traditional Medicare in 2022. Always verify Medicare eligibility to determine plan coverage.
CMS Resources for VBID 2022
Direct link to excel spreadsheet for 2022 VBID MA contacts, plans, and coverage areas by county-