Hospice Billing

Termination of the Hospice Benefit Component of the VBID Model on 12/31/2024

After carefully considering recent feedback about the increasing operational challenges of the Hospice Benefit Component and limited and decreasing participation among MAOs that may impact a thorough evaluation, CMS has decided to conclude the Hospice Benefit Component as of 12/31/2024, 11:59 p.m. CMS will not accept applications to the previously released CY 2025 Request for Applications for the Hospice Benefit Component of the VBID Model.

Starting 1/1/2025, any hospice services provided to MA enrollees who were previously covered under the Hospice Benefit Component (VBID) will transition back to being covered by Original Medicare, also known as the Medicare FFS Program. This means that financial responsibility for these hospice services will no longer fall under the MA plans but will be handled by Original Medicare instead.

If a patient's hospice election extends beyond the termination date of the Hospice Benefit Component (VBID), hospice providers should not discharge them solely due to their coverage under a plan that was participating in the Hospice Benefit Component (VBID) before CY 2025. Additionally, for those hospice elections that carry over into 2025, there will be no need to submit new NOEs. This ensures continuity of care for patients under hospice and minimizes administrative burdens for hospice providers.

During the model years, hospices were required to submit NOEs and all hospice claims to their MAC for informational purposes, as part of the monitoring and evaluation process. This was intended to ensure a smooth billing transition when Original Medicare assumes financial responsibility after the model concludes.

Starting 1/1/2025, Original Medicare will become financially responsible for sequential claims submitted for services provided on or after that date. If a hospice did not adhere to the informational billing requirements during the model, claims with dates of service from 1/1/2025, onwards that are associated with a late NOE (received 1/6/2025, or later) may incur late NOE penalties. However, exceptions may be made if the delay in submitting a timely NOE was beyond the hospice’s control.

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