Hospice Change of Address

2086 - Hospice Change of Address (Rev. 73, Issued: 12-02-11 Effective: 12-02-11, Implementation: 12-02-11) It is inherent in the provider certification process that a provider notifies CMS of its intent to change the location or site from which it provides services. Absent such notification, CMS has no way of carrying out its statutorily mandated obligation of determining whether the provider is complying with applicable participation requirements at the new site or location. It is a longstanding CMS policy that there is no basis for a provider to bill Medicare for services provided from a site or location that has not been determined to meet applicable requirements of participation. This guidance is contained in Chapter 3, section 3224 of Publication 100-07. When an existing hospice intends to move from its surveyed, certified location to a new site or location, it notifies CMS either directly or through the SA, and, if deemed, it notifies its approved national accreditation organization (AO), in writing of the proposed change of location. The provider also notifies its MAC and submits all required documentation including an amended Form CMS-855A before CMS approval can be granted. The provider obtains CMS’ approval of the new address before it provides Medicare services from the new address. Upon receipt of a provider’s notice and request for approval of the move to the new site or location, the RO will carefully evaluate the information, together with any supporting documentation from the provider and any other relevant information known to the RO in making its decision. If a decision can be made on the written application and supporting documentation, CMS will grant or deny an approval without requiring a survey. If, however, the RO concludes that circumstances warrant a survey to establish whether the new address complies with all applicable requirements, CMS will advise the provider and will make no further findings until a survey has been completed and submitted to CMS for its review. In either event, CMS will notify the provider of its decision in writing, as appropriate. CMS generally will not approve a change of location of a primary hospice with one or more previously approved multiple locations if the new location increases the distance between the primary hospice location and its previously approved multiple location(s) to a point that prevents the hospice from exerting the supervision and control necessary at each multiple location to assure that all hospice care and services continue to be responsive to the needs of the patient/family at all times and in all settings. In that event, the application for approval of the new location would usually be denied without a survey, and the provider would apply for a new certification number for the new location. Request for approval of a proposed change of location of an approved multiple location is handled as a request for approval of a new multiple location, in accordance with the regulations and guidelines at 42 CFR 418.100(f). NOTE: CMS will not approve a change of location for a hospice’s own inpatient facility without a survey to assure that the facility meets all requirements specified at 42 CFR 418.110. 2086A - Effective Date (Rev. 69, Issued: 12-15-10, Effective: 10-01-10, Implementation: 10-01-10) A hospice may not bill for services provided from the new site or location and should not bill Medicare until the new site or location has been approved by CMS. The effective date of coverage for services provided from the new location is the date CMS grants approval to the hospice’s request to change locations. The fact that a national AO has approved a new site or location will not affect CMS’ decision. CMS’ determination will be based on its independent application of its regulations to the facts in the case. Services provided before the effective date of approval should not be billed to Medicare. 2086B – Administrative Review (Rev. 73, Issued: 12-02-11 Effective: 12-02-11, Implementation: 12-02-11) CMS’s decision on a request for approval of a change of address does not qualify as an initial determination subject to administrative review under 42 CFR 498.3. Such a determination does not affect the existing provider agreement, which continues in effect at the surveyed, certified location until voluntarily terminated by the provider pursuant to 42 CFR 489.52 or involuntarily terminated by CMS pursuant to 42 CFR 489.53. In the event approval of the new change of address is denied, the provider has the option of formally applying for initial certification of the new site or location as a separate Medicare provider of hospice services. In that event, an initial certification survey by CMS or the SA (or accreditation based on survey by a national AO with deeming authority) would be required. 2086C – Move after Certification Survey (Rev. 73, Issued: 12-02-11 Effective: 12-02-11, Implementation: 12-02-11) Requests for initial certification cannot be processed to completion if a prospective provider moves to a new location after it is surveyed and/or deemed to meet the CoPs by a national AO with deeming authority. If a prospective provider moves after its location has been surveyed and/or accredited but prior to a certification determination by CMS, the prospective provider’s application for certification becomes incomplete. Absent a survey of the new location to which the prospective provider has moved, CMS is unable to determine whether applicable program requirements are met at the new location, and therefore is prevented from completing its review of the pending application. In these circumstances, CMS advises the prospective provider that its application is incomplete. Such an incomplete application is held in abeyance pending receipt of a report of survey of the current location from the SA or a national AO with deeming authority meeting the requirements of and approved by CMS. The decision to hold an incomplete application in abeyance does not qualify as an initial determination as defined in 42 CFR 498.3.