CMS Updates Hospice Certifying Physician Enrollment Guidance, Again
(June 11, 2024) On Thurs., June 6th, the Centers for Medicare and Medicaid Services (CMS) published an update to Frequently Asked Questions (FAQs) for the hospice certifying physician enrollment requirement to better align with current hospice regulations and provide clarity around the process of recertifying patients.
Originally, as part of the implementation of this proposal from the Fiscal Year (FY) 2024 Hospice Rule, CMS was mandating that any individual who revoked or was discharged from the hospice benefit, then re-elected to receive the hospice benefit during the next available benefit period, would need to be recertified “as if entering the program in an initial benefit period,” and that the certifying physician or physicians must be enrolled or opted out as specified in rules. This is inconsistent with regulation and statute governing the hospice benefit and would have had major negative impacts on patients and families looking to re-enroll in hospice services in the future. LeadingAge supports this positive correction from CMS.
This is not the first correction or change to this guidance. CMS previously delayed the implementation date of these requirements from May 1st to June 3rd in response to ongoing concerns. CMS anticipates that additional instructions in the claims processing manual will be implemented and published in October. The FAQs provide a high-level overview of how to complete the claim form and how it will be verified. CMS also made a clarification regarding a nurse practitioner (NP) or physician assistant (PA) listed in the Attending Physician field. In the updated guidance, CMS clarifies that for recertification claims submitted on or after Oct. 7th with dates of service June 3, 2024 or later, if the patient’s designated attending is an NP or PA, hospices must enter the NP or PA in the Attending Physician field and the certifying physician in the Other/Referring Physician field. However, on the initial certification, the claim will be denied if the NP or PA is in the Attending Physician line, since both the hospice physician and the attending physician must certify, and a PA and NP do not meet the definition of “physician” specified in 42 CFR § 410.20(b).
Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871