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Hospital claim closing: how to reduce discharge-to-bill time

Discharge-to-bill time is the delay that depends only on the hospital. How Brazilian hospitals measure it, why accounts stall after discharge and the practices that close the account faster.

By Published on 10 min read

What is discharge-to-bill time?

It is the number of days an account takes from the patient's discharge to submission to the health plan. The metric answers a simple question: once care ends, how long does the hospital take to bill?

Also called discharge-to-submission time, it covers stages 5 and 6 of the hospital revenue cycle: account closing and audit, then billing and submission. No health plan deadline is running in this segment. Every day of waiting comes from an internal pending item.

At hospitals in the National Association of Private Hospitals (Associação Nacional de Hospitais Privados, Anahp), health plans (operadoras) accounted for 76.47% of gross revenue in 2025 [2]. Health plans are regulated by the National Supplementary Health Agency (Agência Nacional de Saúde Suplementar, ANS). Claims go out electronically in the TISS standard (Troca de Informações na Saúde Suplementar), the ANS data exchange standard. The Hospital billing pillar recommends measuring this interval separately, because it shows how much of the payment delay belongs to the hospital.

At Anahp member hospitals, average days to payment was 77.35 in 2025 [2]. That figure does not show how many days accounts spent inside the hospital before being billed.

An account goes through four milestones and three segments

An account changes status on four dates: discharge, closing, submission and payment. There are three segments between them, and only the last depends on the health plan.

From discharge to submission, the clock belongs to the hospitalTimeline of a hospital account with four milestones: discharge, account closing, submission with protocol number, and payment. Segment 1, discharge to closing: pending medical record items, charges, OPME, authorization and audit; matches the HFMA DNFB balance. Segment 2, closing to submission: the health plan's batch calendar and TISS XML validation; matches the FBNS balance. Segments 1 and 2 make up discharge-to-submission time, which depends only on the hospital. Segment 3, submission to payment: health plan review, denial, appeal and payment; the ANS average payment time counts from the protocol. A marker shows the contract submission deadline, after which the claim can be denied for late billing, codes 3214 and 3161 of TUSS table 38. From discharge to submission, the clock belongs to the hospital Four milestones, three segments: the health plan only starts counting at the submission protocol Discharge-to-submission time: up to the hospital alone Up to the health plan HFMA balance: DNFB HFMA balance: FBNS Discharge Account closing Submission (protocol) Payment Segment 1 · discharge → closing Medical record, charges, OPME, authorization, audit Segment 2 · closing → submission Health plan batch calendar, TISS XML validation Segment 3 · submission → payment Health plan review, denial, appeal, payment Contract submission deadline: after it, denial for late billing (TUSS table 38: 3214, 3161) ● ANS average payment time counts from the protocol Sources: HFMA MAP Keys (PB-1, PB-2); ANS, Technical Note 25/2020 (denial dashboard); ANS, TUSS table 38; Law 9,656/1998, art. 17-A. Produced by Accrua.
Hospital account timeline: the hospital controls the time from discharge to submission; the health plan, from submission to payment. Sources: HFMA MAP Keys; ANS, Technical Note 25/2020; ANS, TUSS table 38; Law 9,656/1998, art. 17-A. Produced by Accrua.
See the segments as a table
SegmentFromToWhat holds the accountWho controls it
1DischargeAccount closingMedical record, charges, OPME, authorization, audit (DNFB balance)Hospital
2Account closingSubmission (protocol)Health plan batch calendar, TISS XML validation (FBNS balance)Hospital
3Submission (protocol)PaymentHealth plan review, denial, appeal, paymentHealth plan
MilestoneWhat it recordsWhere to find the dateWatch out
DischargeEnd of care (inpatient stay) or of the billed period (interim bill)Hospital management system; TISS admission or discharge notice, which must be electronic [7]A discharge entered late in the system hides days of stalled account
ClosingAccount reviewed, audited and ready to generate the TISS formsAccount status in the systemUse a single “closed” status; reopened accounts reset the clock
SubmissionAccount transmitted to the health plan in an XML batchBatch protocol number and dateA rejected batch is not a submission; use the date of the accepted resubmission
PaymentAmount received and reconciledPayment statement and bank recordOutside this metric; part of days to payment

The first segment, discharge to closing, holds most documentation, charge capture and authorization issues. The second, closing to submission, depends on each health plan's submission calendar and on file validation. The third is the health plan's review and payment.

The Healthcare Financial Management Association (HFMA) splits the first two segments into two balances [1]. DNFB (discharged not final billed) covers discharged accounts without a final bill. FBNS (final billed not submitted) covers accounts already closed but held by pre-submission edits or rejected at transmission [1]. The guide Discharged not final billed (DNFB) covers those balances in reais and days of revenue.

How to calculate discharge-to-bill time

The calculation uses the accounts submitted in the period and each account's dates:

Average discharge-to-submission time (days) = sum of (submission date − discharge date) for accounts submitted in the period ÷ number of accounts submitted in the period

The formula is this guide's proposal, not an HFMA or ANS rule. HFMA has no per-account discharge-to-bill key. DNFB is a month-end snapshot of the balance, and charge lag (PB-4) measures the days between service and charge posting for each item [1]. What matters is writing the definition down and keeping it every month.

Four choices prevent misleading numbers:

  • Mean and median together. A few very late accounts pull the mean up. The median shows the typical account; the gap between the two shows the size of the tail.
  • Split by segment. Calculate discharge → closing and closing → submission separately. If the second is long, the problem is the batch calendar or file edits, not account review.
  • Interim bills use the period date. The TUSS (Terminologia Unificada da Saúde Suplementar, the ANS unified terminology) classifies billing as interim, final, complementary or total (table 55) [8]. For an interim bill, use the end date of the billed period instead of discharge; measure complementary bills separately so late charges do not mix with normal closing.
  • Read it with DNFB. The average only sees accounts already submitted. An account stalled for 60 days does not enter the calculation until it is sent; DNFB shows it today.

Illustrative example. In one month, a hospital submitted five accounts with 3, 4, 5, 6 and 32 days between discharge and submission. The mean is 10 days; the median, 5. The 32-day account, a stay waiting for an OPME (implants and special materials) invoice, more than doubled the mean on its own (without it, the mean would be 4.5 days). The split showed 27 days to closing and 5 to submission.

Why do accounts stall after discharge?

An account stalls because something is missing to close or submit it. Each cause shows up in one segment and has a different owner. The table lists those that often appear in hospitals that bill health plans.

CauseSegmentOwnerPractice that shortens the time
Discharge entered late in the systemBefore closingInpatient units and admissionsDischarge recorded in the same shift and TISS discharge notice [7]
Incomplete medical record (progress notes, checked orders, operative report, discharge summary)Discharge → closingPhysicians and nursingDischarge checklist reviewed before the patient leaves
Late charges for supplies and drugsDischarge → closingPharmacy, operating room, care unitsPoint-of-use charge capture; HFMA treats charges posted more than 3 days after service as late [1]
OPME without invoice, traceability label or authorizationDischarge → closingSupply chain and authorization teamItem documentation checked in the operating room
Pending extension or authorizationDischarge → closingAuthorization teamExtension requested before authorized days run out
Medical team or physician fees not reportedDischarge → closingBilling and medical staffTeam recorded from the surgical schedule
Internal audit queueDischarge → closingInternal auditConcurrent audit during the stay
Waiting for the health plan's submission calendarClosing → submissionBillingSubmission calendar by health plan with each cutoff date
Edits or rejection of the TISS XML batchClosing → submissionBilling and ITFile validation before transmission

Two causes deserve separate attention. The first is reopening: a closed account sent back for a pending item loses its place in the queue and adds days to both segments. Counting reopenings by reason shows where review is failing.

The second is long stays. Without interim billing, revenue from a stay of several weeks is billed only after discharge, and the large account takes longer to audit. When the contract allows it, interim billing brings billing forward; see the guide Interim billing.

Delay costs cash and can become a denial

Delay costs in two ways: idle cash and the risk of missing the submission deadline. Both grow with every day the account waits.

Idle cash. The hospital has already paid for the care, but billing has not started. On the ANS denial dashboard, average payment time is counted from the billing protocol, not from the date of care [6]. Days before submission do not appear in the health plan's numbers, but they weigh on the hospital's working capital.

Illustrative example. A hospital with gross health plan revenue of BRL 300 thousand per day cuts average discharge-to-submission time by 5 days. Cash receives a one-time gain of about BRL 1.5 million (5 × BRL 300 thousand). At a capital cost of 1% per month, that idle amount cost close to BRL 15 thousand per month. The guide Cost of payer delays shows the calculation with the hospital's own rate.

Submission deadline. Law 9,656/1998, art. 17-A, § 2, II, requires the contract between health plan and provider to set deadlines and procedures for billing and payment [3]. RN 503/2022, which regulates these contracts, sets no number of days for submission [4]. Each contract sets its own deadline.

When an account is submitted after that deadline, the health plan can issue a denial. TUSS table 38 has codes for this case. They include 3214, “billing outside the deadline set in the contract with the provider”, and 3161, “submission outside the contract period agreed between the parties” [5]. Anahp's contracting manual states that treating an account as time-barred because of late submission “has been considered illegal by the Judiciary” [9]. That is the association's position; in practice, the safest course is to submit on time.

Practices to close accounts faster

Closing accounts faster means clearing pending items before discharge and giving each remaining item an owner after it. These practices address both segments and can start without changing systems:

  1. Build the account during the stay. Concurrent audit reviews the account while the patient is in the hospital, so fewer pending items remain at discharge. See the guide Types of claims audit.
  2. Discharge checklist. Before the patient leaves, the unit checks the discharge summary, checked orders, operative report and OPME records.
  3. Daily queue by age and amount. Every day, the billing coordinator receives the list of discharged accounts not yet submitted, with discharge date, health plan, amount, segment and pending reason.
  4. Internal deadline by segment. The hospital sets how many days each area has to answer its pending item. The deadline comes from the hospital's own series and from the contract submission deadline, not from an external benchmark.
  5. Submission calendar by health plan. A table with each health plan's cutoff date, batch frequency and contract deadline keeps closed accounts from waiting for the next cycle without need.
  6. Validate the XML before the batch. Edits fixed before transmission avoid rejection and resubmission. See the guide TISS XML errors.

What is a good discharge-to-bill time?

There is no public benchmark. HFMA's MAP Keys page publishes no numeric target for pre-billing metrics [1], and in Brazil no primary source publishes an industry average for this interval.

The usable benchmark is the hospital's own, within two limits. The first is each health plan's contract submission deadline: the internal deadline needs a margin before it. The second is the hospital's own series: measure three months, split by segment and cause, and set a reduction target on the median.

What we see in operations

At Accrua, the stretch between discharge and submission is the first thing we measure, because it is the only one where the clock depends on the hospital alone. When we read a hospital's history, we split the two stretches this guide describes, discharge to close and close to submission, and look claim by claim at where the days pile up: OPME without an invoice or label, an incomplete medical record, a pending extension.

Accrua OS runs on top of the hospital's HIS/ERP and tracks each open claim against the submission deadline in the contract with that health plan. Agents handle what has a rule: XML validation, submission, deadline and status tracking. When a document is missing, the task goes to whoever can solve it, with the source shown.

In our managed operation, billers and auditors with nursing backgrounds work stalled claims by cause, not by arrival order. And when the issue is cash, Receita Garantida puts the value of eligible production into the hospital's account when it needs it.

Where to start

  1. Write the definition: which dates mark discharge, closing and submission, and how to treat interim bills, complementary bills and rejected batches.
  2. Calculate the mean and median for accounts submitted last month, splitting discharge → closing and closing → submission.
  3. Classify late accounts by cause and name an owner and an internal deadline for each.
  4. Build the submission calendar by health plan, with cutoff date and contract deadline.
  5. Track it weekly alongside DNFB and set the target from the first three months.

Frequently asked questions about discharge-to-bill time

What is discharge-to-bill time?

It is the average number of days between a patient's discharge and submission of the claim to the health plan. It shows how much of the payment delay happens inside the hospital, before billing starts.

How do you calculate discharge-to-submission time?

For each account submitted in the period, count the days between the discharge date and the submission protocol date, add them up and divide by the number of accounts. Also track the median and split the segments up to closing and up to submission.

Is there a legal deadline for Brazilian hospitals to submit claims to health plans?

No number of days is set in law or in RN 503/2022. Law 9,656/1998, art. 17-A, requires the contract to set billing deadlines, and each contract sets its own.

Can a late claim be denied?

Yes. TUSS table 38 has codes for this, such as 3214, “billing outside the deadline set in the contract with the provider”, and 3161, for submission outside the contract period.

What is the difference between discharge-to-bill time and DNFB?

Discharge-to-bill time is an average duration for accounts already submitted. DNFB is the balance, in reais or days of revenue, of discharged accounts not yet billed. One complements the other.

What is the target for discharge-to-bill time?

HFMA publishes no public target and Brazil has no industry benchmark. Each hospital sets its own from its series, with a margin before each health plan's contract deadline.

Sources

  1. HFMA — MAP Keys: Pre-Billing (PB-1 Days in Total DNFB, PB-2 Final Billed Not Submitted to Payer, PB-3 DNSP, PB-4 Total Charge Lag Days) and Claims (CL-2 Late Charges as a % of Total Charges), accessed 10/17/2026.
  2. Anahp — Balanço Observatório Anahp (Anahp Observatory Report), 9th edition, March 2026 (2025 data), chart 10, p. 27.
  3. Lei nº 9.656, de 3 de junho de 1998 (Law 9,656 of June 3, 1998), art. 17-A, § 2, II (added by Law 13,003/2014).
  4. ANS — Resolução Normativa nº 503 (Normative Resolution 503), March 30, 2022 (payer–provider contracts; Official Gazette, 04/04/2022).
  5. ANS — TUSS, table 38 (denial messages), version 202607, official ANS “Demais terminologias” spreadsheet, checked on 10/18/2026: codes 3214 (in force since 12/01/2025) and 3161 (in force since 08/01/2021).
  6. ANS — Nota Técnica nº 25/2020/GASNT (Technical Note 25/2020), Painel de Indicadores de Glosa (denial indicators dashboard), items 16 to 21.
  7. ANS — Padrão TISS: Componente Organizacional (TISS standard: Organizational Component), version 202609 (September 2026), item 33.
  8. ANS — TUSS, table 55 (billing type: 1 interim, 2 final, 3 complementary, 4 total), version 202607, official ANS “Demais terminologias” spreadsheet, checked on 10/18/2026.
  9. Anahp — Manual de contratualização entre hospitais e operadoras (Hospital–health plan contracting manual), 2025, section 7.