Hospice Billing

Appropriate Use of Occurrence Code 27 and Occurrence Span Code 77

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Appropriate Use of Occurrence Code 27 and Occurrence Span Code 77

Hospice care is available for two periods of 90 days and an unlimited number of subsequent 60-day periods. Certification of the terminal illness is required at the start of each benefit period. The hospice must obtain, no later than two calendar days after the start of each hospice benefit period, oral or written certification of the terminal illness. Initial certifications may be completed up to 15 days before hospice care is elected. For the subsequent periods, recertifications may be completed up to 15 days before the next benefit period begins. If an oral certification is received, the written certification must be on file in the hospice patient’s record prior to submission of a claim to the Medicare contractor.

When the certification/recertification is done timely, OC 27 is reported on the claim for the billing period that crosses the new/next election period. The OC 27 date must equal the start date of the next election period. Note that the OC 27 date will create the next election period if one is not currently present. The OC 27 is not reported on claims that do not cross a new election period.

When the recertification is not done timely, an OSC 77 must be reported to represent for the days that are provided-liable due to the late recertification. The OC 27 is reported with the date that the actual recertification was obtained. As of 1/1/2017, the CMS has developed a new CC 85, to use when reporting OSC 77 for an untimely certification. The new CC 85 is defined, “Delayed recertification of hospice terminal illness." When hospices report this code, Medicare systems will ensure the occurrence code 27 date(s) does not fall within the OSC 77 dates when reporting OSC 77 for untimely certification.

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Example of the Proper Use of OC 27

When certifications/recertifications are obtained timely, the OC 27 date reported will match the start date of the election period. For example, the patient is admitted to hospice for the first time on 5/8/20XX and revokes the benefit on 9/6/20XX. The initial certification was done on 5/7/20XX, and the recertification was done on 8/6/20XX. The election periods are as follows:

Election Period 1 Election Period 2
Start Date: 5/8/20XX Start Date:8/6/20XX
End Date: 8/5/20XX End Date: 9/6/20XX


The OC 27 will only be reported on the claims with dates of service that cross the new/next election period.

Claim 1 2 3 4 5
Type of Bill 8X2 8X3 8X3 8X3 8X4
Dates of service 5/8/20XX- 5/31/20XX 6/1/20XX-6/30/20XX 7/1/20XX-7/31/20XX 8/1/20XX-8/31/20XX 9/1/20XX-9/6/20XX
OC 27? Yes No* No* Yes No*
OC 27 Date 5/8/20XX N/A N/A 8/6/20XX N/A
*OC 27 is not reported because the claim is not crossing a new hospice election period.

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Example of the Proper Use of OC 27 with OSC 77 and CC85 (effective 1/1/2017)

When recertifications are not obtained timely, hospices must report OSC 77 to identify the days of care that are not covered by Medicare due to the untimely physician recertification. The OC 27 date reported will match the actual date that the recertification was obtained. As of 1/1/2017, the CC 85 is used to indicate the use of OSC 77 for a late recertification.

*Note: Hospice claims will continue to be RTP if the OC 27 date on a hospice claim falls within the OSC 77 to indicate that there are noncovered provider liable days for an untimely physician certification.

Below are two examples of the appropriate use of OC 27 and OSC77.

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Example 1

The patient is admitted to hospice for the first time on 10/15/20XX and revokes the benefit on 1/29/20XX. The initial certification was done on 10/15/20XX, and the recertification was done on 1/19/20XX.

The election periods are as follows:

Election Period 1 Election Period 2
Start Date: 10/15/20XX Start Date: 1/13/20XX
End Date: 1/12/20XX End Date: 1/29/20XX


The OC 27 will be reported on the initial claim. Since the recertification was obtained late, the OSC 77 will be reported to reflect the days that are not covered by Medicare. Effective 1/1/2017, the CC 85 will be used to report the use of OSC 77 for noncovered provider liable days for a later recertification.

The OSC 77 start date will be the first day of the election period where the recertification was obtained late. The OSC 77 end date will be the day before the actual recertification was obtained. OC 27 will then reflect the date that the actual late recertification was obtained.

Claim 1 2 3 4
Type of Bill 8X2 8X3 8X3 8X3
Dates of service 10/15/20XX-10/31/20XX 11/1/20XX-11/30/20XX 12/1/20XX-12/31/20XX 1/1/20XX-1/29/20XX
OC 27? Yes No* No* Yes
OC 27 Date 10/15/20XX N/A N/A 1/19/20XX
OSC 77? No No No Yes†
OSC 77 Dates N/A N/A N/A 1/13/20XX-1/18/20XX
CC 85? No No No Yes
*OC 27 is not reported because the claim is not crossing a new hospice election period.
†OSC 77 is reported to show the provider-liable days due to the late recertification

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Example 2

The patient is admitted to hospice for the first time on 9/28/20XX and revokes the benefit on 1/22/20XX. The initial certification was done on 9/18/20XX, and the recertification was done on 1/2/20XX. The election periods are as follows:

Election Period 1 Election Period 2
Start Date: 9/28/20XX Start Date:12/27/20XX
End Date: 12/26/20XX End Date: 1/22/20XX


The OC 27 will be reported on the initial claim. Since the recertification was obtained late, the OSC 77 will be reported to reflect the days that are not covered by Medicare. The CC 85 will be reported to indicate the OSC 77 is used for a later re-certification.

When a provider-liable period crosses a billing cycle, the OSC 77 will be reported on both claims that have provider-liable days with CC 85. Therefore, the OSC 77 start date on the first claim that has provider-liable days will be the first day of the election period where the recertification was obtained late, and the end date will be the last day of the billing period. The OSC 77 start date on the second claim will be the first day of the billing period, and the end date will be the day before the actual recertification was obtained. OC 27 will then reflect the date that the actual late recertification was obtained.

Claim 1 2 3 4 5
Type of Bill 8X2 8X3 8X3 8X3 8X4
Dates of service 9/28/20XX-9/30/20XX 10/1/20XX-10/31/20XX 11/1/20XX-11/30/20XX 12/1/20XX-12/31/20XX 1/1/20XX-1/22/20XX
OC 27? Yes No* No* No** Yes
OC 27 Date 9/28/20XX N/A N/A N/A 1/2/20XX
OSC 77? No No No Yes† Yes†
OSC 77 Dates N/A N/A N/A 12/27/20XX-12/31/20XX 1/1/20XX-1/1/20XX
CC 85 No No No Yes Yes
*OC 27 is not reported because the claim is not crossing a new hospice election period.
**OC 27 is not reported because the late certification was not obtained within the billing period
† OSC 77 is reported to show the provider-liable days due to the late certification


Transfer Patients and the Use of OC 27

If a patient is in the first certification period when they transfer to another hospice, the receiving hospice would use the same certification date as the previous hospice until the next certification period. However, if the beneficiary was in the next certification at the time of transfer, then they would enter the date in the OC 27 and the date.

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Revised 5/14/2018