Medicare Hospice benefit and replacements

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Who should be billed for the pre-admission ambulance transport when the patient has a Medicare replacement policy?

"According to the Centers for Medicare & Medicaid Services (CMS) Internet Only Manual (IOM) Publication 100-04, Chapter 11, Section 40.2.2, when a Medicare Advantage patient elects hospice coverage, all services come back to Medicare Fee-For-Service. This is true whether the services are related or unrelated to the hospice condition. "
See CMS IOM Publication 100-04, Chapter 11, Section 40.1.3.

But there seems to be some confusion between Medicare and the replacement carrier as to who should pay when the DATE is the first day of hospice coverage, and pre admission. Medicare does have the GW modifier for use when the transport occurs prior to the actual assessment and admisssion.

However, transports billed in this way are often denied for a CO109 "Claim not payable by this payor". But the same claim filed to the replacement policy, will be denied for hospice!

Thank you!
 
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