Multiple Locations

2088 – Multiple Locations (Rev. 69, Issued: 12-15-10, Effective: 10-01-10, Implementation: 10-01-10) When an existing hospice intends to add a multiple location, it must notify CMS, the SA, and, if deemed, it should notify its’ approved national AO, in writing, of the proposed location if it expects this location to participate in Medicare or Medicaid. The hospice must also submit a Form CMS-855A Change of Information Request (including all supporting documentation) to its MAC before CMS approval can be granted. The provider must obtain CMS approval of the new location before it is permitted to bill Medicare for services provided from the new location. Upon receipt of a hospice’s notice and request for approval of a multiple location, the CMS RO will carefully evaluate the information, together with any supporting documentation from the hospice and any other relevant information known to the RO in making its decision. If a decision can be made based 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 location complies with all applicable requirements, CMS will advise the provider and will make no further findings until a Medicare certification 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. In evaluating a hospice’s request for approval of a multiple location, the SA and RO should consider the following in determining whether the new location meets all applicable Medicare requirements: • Ability of the governing body to manage the location; • Any changes made to the lines of authority, and professional and administrative control; • Ability of the Medical Director to assume responsibility for the medical component of the hospice’s patient care at all locations; • Ability of the hospice to monitor and exercise control over services provided by personnel under arrangements or contracts at the multiple location; • Changes in the IDG(s) providing hospice services; • Changes in staffing or the client population, or both; • Changes in the way clinical records are maintained, protected and safeguarded against loss, destruction or unauthorized use; and • Ability of the hospice to provide all hospice services at the multiple location. A hospice may not bill Medicare for services provided from a multiple location until the new site or location has been approved by CMS. The fact that a national AO with deeming authority 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. If the hospice does operate at multiple locations, a deficiency found at any location will result in a compliance issue for the entire hospice. For further information on hospice multiple locations, see 42 CFR 418.100(f) and 418.116.