I work for an organization that provides Hospice and Palliative Care services. We know that if we previously saw a patient in PC within the past 3 years, that we are not able to bill as a new patient if they re-admit to PC services. My question is if we have a patient in PC that is now Hospice appropriate, can it be billed as initial? We bill under the same Tax ID, but have different NPI and taxonomy codes for each program, and obviously, one is Part A and the other Part B.

On the same note, if we previously saw a patient for PC services during a hospital admission, but did not follow them on an outpatient basis, can we bill as a new patient 2 1/2 years later as an outpatient?

Thank you for any insight that may be provided.

HLM