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Transfer Dispute Between HHAs

Medicare Claims Processing Manual (CMS Pub. 100-04, Ch.10, §§10.1.13, 20.1.1, 20.1.2, 20.1.3, 30.1, 30.3External PDF)

In the rare circumstance of a dispute between HHAs, if the receiving HHA can provide documentation of its notice of patient rights on Medicare payment liability provided to the patient upon transfer and the contact of the initial HHA on the transfer date, then the initial HHA will be ineligible for a full episode payment, but will receive a Partial Episode Payment (PEP). If the receiving HHA cannot provide the appropriate documentation, the receiving HHA's RAP and/or final claim may be cancelled and full episode payment will be provided to the initial HHA.

HHAs should be aware that a transfer dispute does not exist if a beneficiary was discharged from "Agency A" during a 60-day episode or a 30-day period of care under the Patient-Driven Groupings Model (PDGM), and is subsequently re-admitted to "Agency B" when there are no overlapping dates of service between the date of discharge, and second admission date. A discharge from home health care would be evidenced by a patient status code other than "30".

In addition, if a beneficiary was receiving home health services from another HHA within 60/30 days of the second HHA's episode start date, CGS will review the patient status code submitted on the first HHA's episode when there is a dispute as to which HHA is the primary agency. If the patient status code indicates that the beneficiary was still a patient of the first HHA, the second HHA will need to produce documentation indicating the beneficiary transferred to their HHA in order for their episode to stand.

The Centers for Medicare & Medicaid Services (CMS) guidelines require that in the event a transfer dispute occurs, HHAs must first attempt to resolve the transfer dispute among themselves. Refer to the Medicare Benefit Policy Manual (CMS Pub. 100-02, Ch. 7 §10.7.D)External PDFfor additional information.

The initial HHA must make at least three contacts with the receiving HHA. For each contact, the documentation should include the date and time of contact and name of the person contacted. If HHAs are not successful in resolving the transfer dispute, they may request assistance from their Medicare Administrative Contractor (MAC). To report a dispute of transfer, the initial HHA should submit the Notification of Disputed Home Health Agency (HHA) Transfer FormPDFif they bill their home health services to CGS. We would encourage you to print this form from our website each time it is needed to ensure you are using the most current form. Prior to submitting this form to CGS, HHAs should review the important reminders below:

  • Ensure the information on the completed form is legible. Forms that are illegible will be returned to you.
  • Return completed forms via fax or U.S. Mail.
  • The form must clearly document the HHA's attempt to resolve the dispute with the other HHA or it will not be accepted.
  • All admission documentation must be submitted with the transfer dispute form. If this documentation is not included, the case will be closed, and you will be contacted by telephone advising you to submit a new form with the required admission paperwork. CGS will not initiate an investigation into the transfer dispute unless both the needed documentation and "Notification of Disputed Home Health Agency (HHA) Transfer" form are received.

Upon initiating a transfer dispute investigation, CGS will request documentation from the receiving agency. A beneficiary eligibility inquiry screen print dated at the time the receiving agency admitted the beneficiary, and a signed and dated patient consent form are among the most crucial pieces of documentation used by CGS when determining whether the transfer will stand.

HHAs should be aware that resolving transfer disputes can be a lengthy process, especially when the other HHA has a MAC other than CGS.

Note: The "Notification of Disputed Home Health Agency (HHA) Transfer" should not be used when the HHA's services overlap services provided by another Medicare provider type (e.g. hospice, skilled nursing facility (SNF), inpatient hospital, outpatient hospital, etc.). CGS is not able to assist HHAs with these types of overlapping issues. HHAs will need to work out the overlapping issue with the other provider.

Updated: 03.02.23


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