September 19, 2017
Hospice Sequential Billing Reminder: Reason Code 37402
When a hospice claim is submitted out of sequence, the claim is sent to the Return to Provider (RTP) file (T B9997) with reason code 37402. Reason code 37402 is consistently the top claim submission error (CSE) for hospice providers. From January through August 2017, CSE data shows an average of 2,437 claims per month received the out of sequence error (see graph below). As a Medicare provider, you are responsible to ensure compliance with Medicare regulations; therefore, this article serves as a reminder of the sequential billing requirement. Please share this information with your billing staff and other appropriate staff.
To meet the sequential billing requirements, claims must be:
- Submitted sequentially – This means that January's claim, for example, must be submitted before February's claim can be submitted. The Fiscal Intermediary Standard System (FISS) will search claim history for a prior claim.
- If a prior claim is not found in a finalized or suspended status/location (P B9997, R B9997, D B9997 or S XXXXX), the incoming claim will be sent to the RTP file with reason code 37402.
- If the prior claim is in the RTP file (T B9997) and needs correcting, the incoming claim will be sent to the RTP file with reason code 37402. FISS does not search the RTP file (T B9997) for prior claims.
Note: You must correct the claims out of RTP sequentially. For example if the January claim is in RTP because of an invalid HCPC code, and the February claim was submitted, the February claim will go to RTP because no prior claim was found. You must first correct the January claim out of RTP. Once the January claim is corrected and moves to a suspended status/location, the February claim can be F9ed out of RTP.
- If the prior claim is in a suspended status/location (S XXXXX) the incoming claim will move to a suspended status/location until the prior claim has been finalized. Once the prior claim has finalized (P B9997, R B9997, or D B9997), FISS will continue processing the incoming claim.
At any time while a claim is processing, it may move to the RTP file. CGS suggests monitoring your claims on a regular basis. If a prior claim is in RTP, make any necessary corrections to the claim to allow continued processing. To determine the status/location of your claim, refer to the Checking Claim Status Web page. - Submitted consecutively – This means that there cannot be any skip in dates between the prior claim's "TO" date, and the next month's claim's "FROM" date.
- Submitted monthly – Hospices are required to bill claims monthly (see Medicare Claims Processing Manual (CMS Pub. 100-04), Ch. 11, §90
). This means providers should bill only one claim per month, for each patient. The "To" date on the claim must be the last calendar day of the month, unless the patient died, was discharged or revoked hospice during the month.
In addition, hospice claims must conform to a calendar month (Jan 1 – Jan 31). Claims that span two months (ex. Jan 1-Feb 1) will be sent to the RTP file for you to correct.
The Hospice Sequential Billing Web page provides steps you can follow to ensure compliance and to avoid sequential billing errors. Please share this with your appropriate staff and consider developing an internal process to avoid this CSE, which will save you time and money.