On July 27, 2017, CMS issued Change Request 10064 describing a new process for submitting NOEs. This system, to be introduced in January of 2018, will allow hospices to use their billing software to create special claim files in the ANSI 837i format that contain NOE information.
The MACs will then receive these files just as they do actual claims. When they arrive, they will strip out the non-NOE data and post what would normally have been keyed into the FISS system as if it had been done manually through DDE. From this point, the transaction will be processed identically regardless of which method was used to deliver it, the 837i or DDE.
CMS developed this solution with help from NAHC. It is a significant effort to provide a path for providers and their vendors to develop solutions that could reduce the financial impact of keying errors that cause a majority of the rejected NOEs and associated penalties.
The idea of this project is to create a new “front end” to the FISS system, replacing the DDE screens with an industry standard record layout that could be used to submit this data system to system, as is done with claims.
The way the data will be delivered is through the 837i. This specification has been the required standard for all hospice claims (Institutional Provider Claims) for the last twenty years. This process, if implemented as it was intended, would provide two opportunities for validating the NOE data. First, by the vendor when the 837i is created, then by CMS when the claim batch is edited and a 277CA claim status report is returned. The data entry process through DDE has no edits to verify data entered manually.
On the surface, the idea seems simple enough. However, actually implementing it will not be easy.
First, creating the 837i. This transaction is used to send claim data to health plans for payment. It is created by most providers through their patient accounting systems or EMR. For hospices, it is usually processed on a monthly basis or when patients are discharged. The data used in this transaction is normally collected and verified after admission. With the NOE, the transaction must be sent immediately, as soon as the data is ready. If it is not sent within five days of admission, the provider is subject to non-covered services.