CMS SOM App. M, Tag L656

If a hospice operates multiple locations, it must meet the following requirements:

(1) Medicare approval.

(i) All hospice multiple locations must be approved by Medicare before

providing hospice care and services to Medicare patients.

Interpretive Guidelines §418.100(f)(1)(i)

It is inherent in the provider certification process for a hospice to notify CMS of its

proposal to add a location from which it provides services. Absent such notification,

CMS has no way of carrying out the statutorily mandated obligation of determining

whether the hospice is complying with all applicable participation requirements at the

new location. It is a longstanding CMS policy that there is no basis for a provider to bill

Medicare for services provided from a location that has not been determined to meet

applicable requirements of participation.

When an existing hospice intends to add a multiple location, it must notify CMS, the

State Survey Agency (SA), and, if deemed, it should notify its approved national

accreditation organization (AO), in writing of the proposed location if it expects this

location to participate in Medicare or Medicaid. The hospice must also submit a Form

CMS-855A change of information request (including all supporting documentation) to its

Medicare Administrative Contractor (MAC) before CMS approval can be granted. The

provider must also obtain CMS’ approval of the new multiple location before it is

permitted to bill Medicare for services provided from the new location.

NOTE: CMS will not approve a hospice’s inpatient facility or a change of location for a

hospice’s own inpatient facility without a survey to assure that the facility meets

all requirements specified at 42 CFR 418.110.

A hospice may not bill Medicare for services provided from a multiple location until the

new site or location has been approved by CMS. The fact that a national accreditation

organization with deeming authority has approved a new site or location will not affect

CMS’ decision. CMS’ determination will be based on its independent application of its

regulations to the facts in the case. Services provided before the effective date of

approval should not be billed to Medicare.

If the hospice does operate at multiple locations, a deficiency found at any location will

result in a compliance issue for the entire hospice.