On Thursday, June 6, CMS published an update to FAQs for the hospice certifying physician enrollment 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 FY2024 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 reenroll in hospice services in the future.
LeadingAge supports this positive correction from CMS. This isn’t the first correction or change to this guidance. CMS previously delayed the implementation date of these requirements from May 1 to June 3 in response to ongoing concerns. CMS anticipates additional instructions in the claims processing manual will be implemented and published in October.
This Q/A provides a high-level overview of how to complete the claim form and how it will be verified. CMS also clarified if an NP or PA is listed in the Attending. In the updated guidance, CMS clarifies that for recertification claims submitted on or after October 7 with dates of service June 3, 2024, or later, if the patient’s designated attending is a NP or PA, CMS instruct hospices to enter the NP or PA in the Attending Physician 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 does not meet the definition of “physician” specified in 42 CFR § 410.20(b).
