General

1. Question: A patient’s date of death (DOD) was entered incorrectly. How will the correct information flow from the Common Working File (CWF) to the Fiscal Intermediary Shared System (FISS) once the Social Security Administration corrects the DOD on the record?

Answer: Beneficiary eligibility changes on the CWF record update FISS once the first claim is processed after the update in CWF occurs. Eligibility updates flow directly into the HIPAA Eligibility Transaction System (HETS), and those updates are then viewable in Palmetto GBA’s eServices portal which it receives from HETS. Once the DOD is corrected, hospices will need to adjust the claim, if necessary.
 

2. Question: Our hospice administrators and medical directors must now be reported on the CMS-855A Medicare Enrollment Application?

Answer: Yes. In the CY 2024 Home Health Prospective Payment System Final Rule (CMS-1780-F), the Centers for Medicare & Medicaid Services (CMS) clarified that hospice administrators and medical directors must be reported as Managing Employees on the CMS-855A Medicare Enrollment Application. For details, see our article Reporting Hospice Administrators and Medical Directors as Managing Employees on CMS-855A.
 

3. Question: Do we have to list ALL physicians employed by our hospice agency as managing employees on the CMS-855A?

Answer: No. You must list your medical director(s) or physician(s) in an administrative role. CMS recognizes an individual “who directly or indirectly manages, advises, or supervises any element of the practices, finances, or operations of the facility” as a managing employee.
 

4. Question: What specifically does CMS consider as “managing control of the provider”?

Answer: “For purposes of enrollment, such a person is considered a managing employee [which] is any individual, including a general manager, business manager, office manager or administrator, who exercises operational or managerial control over the provider's business, or who conducts the day-to-day operations of the business. A managing employee also includes any individual who is not an actual W-2 employee but who, either under contract or through some other arrangement, manages the day-to-day operations of the business.”
 

5. Question: Who do I contact after receiving the Targeted Probe and Educate (TPE) Final Results?

Answer: The Palmetto GBA Medical Review staff will contact you within two weeks of receiving your TPE Final Results Letter. If you are moving on to a subsequent round, you’ll have 45 to 56 days before it begins, starting from the date of your education session. The reviewer will make a maximum of three attempts to contact the designated individual(s) for your office. If these attempts are unsuccessful, it will be your responsibility to initiate contact with the Medical Reviewer regarding your education session. If this occurs, you will move on to a subsequent round and the 45 to 56-day period will begin on the date of the third missed attempt.

Last Reviewed: 02/05/2026

1. Question: For the hospice cap, do hospices have to use the numbers from the Provider Statistical and Reimbursement (PS&R) System? Or can they use their own numbers which include proportional amounts that do not show on the PS&R?

Answer: Hospices should use the beneficiary count from the most current Beneficiary Summary report pulled from the PS&R System available at the time of Self-Determined Hospice Cap (SDHC) filing. Hospices do not have the ability to accurately account for their beneficiary counts outside of the PS&R system. This is because beneficiary allocations are constantly updated as more paid claims are included in the data pool. 

The beneficiary allocations reported on the Beneficiary Allocation Summary report pulled at the time of SDHC filing is not a final beneficiary allocation number. This number almost always continues to drop as more claims are processed for beneficiaries that were on service in the reporting cap year that continue to receive service in the subsequent cap year(s). Do note that hospice services rendered by other hospices to the same beneficiary are included in the beneficiary count allocation, which is the biggest reason hospices cannot accurately account for their beneficiary count outside of the PS&R system.

For a full explanation of the beneficiary allocation process with examples, please see the Hospice Caps article on the Palmetto GBA website.
 

2. Question: How far back can Palmetto GBA go on hospice cap recalculations?

Answer: Palmetto GBA is required by CMS to do a “look-back” review of the three prior years from the initial cap determination being issued. For example, the initial cap determination of September 30, 2024, cap year includes revisions to the 2023, 2022 and 2021 cap years. The provider is only notified of such revisions if the result is an additional overpayment or refund.
 

3. Question: Some hospices continue to have problems locating a new Medicare Beneficiary Identifier (MBI) when a beneficiary is issued a new MBI. They are trying to work with patients and families to get the new number. In the interim, the inability to process a Notice of Termination/Revocation (NOTR) or final claim is causing billing delays for other Medicare providers.

Answer: The Home Health and Hospice Billing When a New Medicare Beneficiary Identifier Is Assigned article provides direction on using the eServices MBI Lookup tool to receive the current MBI. This should avoid billing delays.
 

4. Question: We are a newly Medicare-certified hospice with beneficiaries on service for our certification process. May we bill for the services provided prior to our effective date or require the beneficiaries to elect on or after our effective date?

Answer: For Medicare payment purposes, an election for Medicare hospice care must be made on or after the date that the hospice provider is Medicare-certified. As with any election, the hospice must fulfill all other admission requirements, such as certification or recertification, any required face-to-face encounters, or Conditions of Participation (CoP) assessments. Resource: Publication 100-02, Medicare Benefit Policy Manual, Chapter 9 — Coverage of Hospice Services Under Hospital Insurance (PDF).
 

5. Question: How can I bill an MSP claim if there is an open worker's compensation, auto or liability file on the common working file, but the services provided are not related to the open file?

Answer: The original claim will reject if diagnosis code(s) on page 5 appears to be related. The provider will need to submit an adjustment with remarks specifying the services are unrelated. The processing unit will review comments and diagnosis codes reported on the claim when making their determination. Please call customer service if you need assistance in preparing the claim.

Resources 

• Publication 100-05, Medicare Secondary Payer Manual (PDF)
• MLN Booklet, Medicare Secondary Payer, MLN006903, July 2025 (PDF)

Last Reviewed: 02/05/2026

1. Question: With a hospice transfer, do both hospices get paid on the date of transfer?

Answer: Yes, both the transferring and receiving hospice can be paid for the date of transfer when a beneficiary changes hospice is permitted to bill and each will be reimbursed at the appropriate level of care for its respective day. For claims purposes the “from" date for the receiving hospice’s claim must be the same as the “through date” for the transferring hospice’s claim. Since both hospices can be reimbursed for the date of transfer, it counts as two days when calculating the hospice routine home care (RHC) high/low rates. When a transfer occurs in the first 60 days of a hospice election, a hospice day billed at the RHC level on day 60 (instead of 61) or later of the hospice election is paid at the low RHC rate.

Resources

• Medicare Learning Network (MLN) Matters® MM12619, Revised: Gap Billing Between Hospice Transfers (PDF)
• Hospice Transfer Requirements
• The Centers for Medicare & Medicaid Services (CMS) Hospice Center
   

2. Question: We are the receiving hospice in a transfer situation, but the transfer between hospices didn’t go as planned. The transferring hospice discharged the beneficiary the day before we admitted the patient, causing a gap in days. What options do we have as the receiving hospice?

Answer: 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 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.

Resources

• MLN Matters® MM12619, Revised: Gap Billing Between Hospice Transfers (PDF)
• Hospice Transfer Requirements
   

3. Question: How does a hospice handle a patient transfer to an agency outside of our service area or in another state?

Answer: If the patient travels outside of the service area, you may discharge the beneficiary. This way, if the patient requires medical treatment while in the process of transferring, he or she can access it under his or her Traditional Medicare fee-for-service coverage. This would end the patient’s current benefit period and require the patient to re-elect hospice coverage at the new hospice and begin a new benefit period. Resource: Hospice Transfer Requirements.
 

4. Question: Where can I find hospice payment rates? Does Palmetto GBA provide them?

Answer: Hospice payment rates are updated annually and published by CMS in the Federal Register before October 1 each year. To assist hospices in obtaining their current hospice rates, Palmetto GBA provides a Hospice Rate Calculator which is available for every state.
 

5. Question: Where can I find hospice cap information?

Answer: You can find information about the hospice caps, including the annual cap amounts, Hospice Cap/Inpatient Day Limitation Calculator, beneficiary allocation and case studies (PDF) on our website.

Last Reviewed: 12/29/2025

1. Question: The dates of service DOS) for my agency’s claim overlap with a Medicare Advantage plan (MA) and hospice elections period. Should I bill the hospice, original Medicare, or the Medicare Advantage plan?

Answer: Federal regulations require that Medicare fee-for-service contractors maintain payment responsibility for managed care enrollees who elect hospice; specifically, regulations at 42CFR Part 417, Subpart P, 42 CFR 417.585 Special Rules: Hospice Care (b), and 42 CFR 417.531 Hospice Care Services (b). eCFR :: 42 CFR 417.585 — Special rules: Hospice care.

While a hospice election is in effect, certain types of claims may be submitted to the MAC by either the hospice provider or a provider treating an illness not related to the terminal condition. The claims are subject to Medicare rules of payment.

• Hospice services covered under the Medicare hospice benefit are billed by the Medicare hospice
• Institutional provider types may submit claims to Medicare with the condition code "07" when services provided are not related to the treatment of the terminal condition
• Medicare Advantage plan enrollees that elect hospice may revoke hospice election at any time, but claims will continue to be paid by the MAC as if the beneficiary were enrolled in Medicare until the first day of the month following the date hospice election was revoked
   

2. Question: Our agency is suddenly receiving multiple remittance advises for claims with an 32I type of bill (TOB). No one in the facility is claiming responsibility for the submission of these claims. Are these claims legitimate or does my facility need to request an investigation?

Answer: There is no need to launch an investigation as the 32I type of bill is valid. When your staff sees claims with that bill type it indicates that the MAC initiated the claim adjustment. Common reasons that 32Is occur include:

• During the quarterly reconciliation process that occurs when an outlier, which was previously unpayable because it exceeded 10 percent of the HHA's total Home Health Prospective Payment System (HH PPS) payments, is now payable due to the subsequent processing of HH PPS claims over the calendar year
• There has been an error identified in previous processing that facilitates the need for the MAC to adjust claim on behalf of the provider community

There is no action that is needed on the behalf of providers when 32I TOBs appear on remittance advice. 
 

3. Question: Where can my agency find detailed information on how to successfully respond to Additional Documentation Request if we are in a state that is involved in the Review Choice Demonstration (RCD)?

Answer: The Palmetto GBA website is a great tool to find out a magnitude of information regarding RCD including appropriately responding the ADR’s received. The checklist can be found using the link Responding to Home Health Additional Documentation Request (ADR) Checklist (PDF). Be sure to follow all the instructions on the ADR to ensure you are providing the information being requested and send to the correct address.

Additional information regarding RCD can be found at: Understanding ADRs When Participating in the RCD and by clicking on the Home Health Review Choice Demonstration (RCD) web page. It contains information such as Frequently Asked Questions , Educational Resources and Pre-Claim Review (PCR) information.
 

4. Question: My agency is receiving Comprehensive Error Rate Testing(CERT) denials stating the signature requirements are not valid on previously processed claims. What information is available to my staff to avoid this from happening in the future?

Answer: The information found in CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 3 Section 3.3.2.4 (PDF) describes what meets the signature requirements to avoid receiving related denials. “For medical review purposes, Medicare requires that the person(s) responsible for the care of the beneficiary, including providing/ordering/certifying items/services for the beneficiary, be identifiable as such in accordance with Medicare billing and coverage policies, such as the Social Security Act §1815(a) and §1833(e). Medicare contractors shall consider the totality of the medical record when reviewing for compliance with the above.

Signatures are required upon medical review for two distinct purposes:

1. To satisfy specific signature requirements in statute, regulation, national coverage determination (NCD) or local coverage determination (LCD); and
2. To resolve authenticity concerns related to legitimacy or falsity of the documentation

If review contractors find reasons for denial unrelated to signature requirements, the reviewer need not proceed to signature authentication.
 

5. Question: Our agency is looking for information regarding the new benefit for Mental Health Counselor for beneficiaries enrolled in a hospice. Where can this information be located so that members of staff can be educated?

Answer: The Consolidated Appropriations Act of 2023 (Pub. L. 117–328) (CAA, 2023), was signed into law on December 29, 2022. Division FF, Section 4121 of the CAA, 2023 (PDF) which established new benefit categories. One of those new benefits were for Mental Health Counselor (NHC) services furnished by and directly billed by the MHC. Section 4121(b)(2) of the CAA, 2023 (PDF) specifically adds these services to covered hospice care services under Section 1861(dd)(2)(B)(i)(III) of the Act.

The CAA, 2023 revised section 1861(dd) of the Act to state that the hospice interdisciplinary group (IDG) is required to include one social worker, MFT, or MHC. To implement Division FF, section 4121 of the CAA, 2023, in the CY 2024 Physician Fee Schedule final rule CMS finalized changes to the regulations at §§ 418.56 and §§ 418.114 to permit MFTs or MHCs to serve as members of the hospice IDG.

Additional useful resources regarding this topic can be found using the following links:

• CMS-1784-F
• CMS IOM, Medicare Benefit Policy Manual, Pub. 100-02, Chapter 9 (PDF)

Answer: A PHE declaration lasts until the Secretary of Health and Human Services declares that the PHE no longer exists or upon the expiration of the 90-day period beginning on the date the Secretary declared a PHE exists, whichever occurs first. The Secretary may extend the PHE declaration for subsequent 90-day periods for as long as the PHE continues to exist and may terminate the declaration whenever the Secretary determines that the PHE has ceased to exist. The declaration was most recently extended on July 15, 2022.

Palmetto GBA provides directions received from CMS on the Palmetto GBA website and through email update messaging. More questions and answers regarding the PHE are available on the U.S. Department of Health and Human Services Public Health Emergency Declaration Q&A web page.

Last Reviewed: 12/29/2025

Answer: The Internet-Only Manual (IOM) System on the CMS website houses the home health and hospice manual information. Please select the following manual references for home health and hospice billing and coverage information. When viewing this information, please select the appropriate provider type to view CMS guidelines.

• Introduction — Publication 100 (PDF)
• Coverage Information: Medicare Benefit Policy Manual — Publication 100-02 
• Billing Information: Medicare Claims Processing Manual — Publication 100-04

Last Reviewed: 12/29/2025

Answer: You can’t adjust a claim to correct a medically denied line. You must submit a Redetermination: 1st Level Appeal form along with a corrected claim.

Last Reviewed: 12/29/2025

Answer: A PTAN is the Provider Transaction Access Number, which is also known as the six-digit provider number, OSCAR number or legacy number. Providers will be asked for their PTAN when calling the provider contact center (PCC).

Last Reviewed: 12/29/2025