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Untimely Recertifications and Occurrence Span Code (OSC) 77

Medicare Claims Processing Manual (Pub. 100-04) Ch. 11, §30.3External PDF

Medicare guidelines require hospices to recertify each patient as terminally ill with each new hospice benefit period. The timeframe for recertifications requires the hospice to obtain verbal or written certification of the terminal illness no later than 2 calendar days (by the end of the 3rd day) after the start of each benefit period. If the hospice does not obtain the recertification within this timeframe, the recertification is considered untimely.

If the recertification is untimely, the hospice must include an Occurrence Span Code (OSC) 77 on their claim to indicate the span of days that were not covered (from day 1 of the benefit period until the recertification was obtained). Due to sequential billing, the dates of service on the claim must reflect the usual 'From' and 'To' dates of service, and include all covered and noncovered days, visits and charges. In additon, condition code 85, defined as “Delayed recertifcation of hospice terminal illness” must be reported (see MM9590 External Website). 

If the recertification was obtained within the billing period (i.e. within the 'From' and 'To' dates on the claim), occurrence code (OC) 27 must be included on the claim. The date billed with OC 27 would be the date the recertification was actually obtained.

If the recertification was not obtained within the billing period, then occurrence code 27 is not required. However, the 'To' date of the claim must equal the 'To' date billed with the OSC 77.

NOTE: Occurrence span code 77 is never used to report an untimely face-to-face (FTF) encounter. For information about billing an untimely FTF, refer to the "Untimely Face-to-Face Encounter" Web page.


A new benefit period began on January 6, and the hospice was required to obtain the recertification (verbal or written) by the end of the day on January 8. However, the hospice did not obtain the recertification until January 14. Therefore, condition code 85 is used because the recertification was untimely, and occurrence span code 77 is used to indicate the noncovered days; January 6 through January 13. Occurrence code 27 is used to indicate the date the recertification was actually obtained; January 14.



Updated: 12.13.18

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