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June 25, 2019

Hospice Sequential Billing Reminder: Reason Code 37402

Medicare regulations require that hospice providers bill on a monthly basis that conforms to a calendar month. ospice providers must also submit claims in date sequence. When a hospice claim is submitted ut 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.

Top Claim Submission Error (CSE)
From September 2018 through May 2019, CSE data showed 18,161 claims received the out of sequence reason code 37402.

37402

As a Medicare provider, it is your responsibility 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. FISS does not search the RTP file (T B9997) for prior claims.
    • When a prior claim is found, but has not yet completed processing, FISS will hold the out of sequence claim until the prior claim has completed processing.

      For example, if the September claim is in a suspended status/location (S XXXXX), the October claim will move to a suspended status/location until the September claim has been finalized. Once the September claim has finalized (P B9997, R B9997, or D B9997) FISS will continue processing the October claim.
    • If the prior hospice claim is not found or if it is in the Return to Provider file (status/location T B9997), the out of sequence subsequent hospice claim will be RTP with reason code 37402.

      For example, if the September claim is in the RTP file for correction, and the October claim is submitted, the October claim will be sent to the RTP file with reason code 37402 because FISS is unable to find the September claim in a suspended status/location (S XXXXX).

      When correcting claims out of the RTP file, they must be corrected sequentially. In this example, you must first correct the September claim out of RTP. Once the September claim is corrected and moves to a suspended status/location (S XXXXX), you can simply press F9 to release the October claim out of RTP.
    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 a gap between the “TO” date and the next month's claim's "FROM" date. For example, when you submit a claim with dates of service 10/15/YY – 10/31/YY, the November claim’s FROM date must be 11/1/YY.  If the November claim is submitted with a FROM date of 11/2/YY, it will go to the RTP file with reason code 37402.
  • Submitted monthly – Hospices are required to bill claims monthly (see Medicare Claims Processing Manual (CMS Pub. 100-04), Ch. 11, §90External PDF). 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 (Oct 1 – Oct 31). Claims that span two months (ex. Oct 1-Nov 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.

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