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Hospice Clinical FAQs

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  1. Is a physician assistant recognized as an attending physician under the Medicare hospice benefit?

    • The Centers for Medicare & Medicaid Services (CMS) does not recognize physician assistants as attending physicians under the hospice benefit.

      CMS has published guidelines regarding the physician and nurse practitioner roles in the Medicare Benefit Policy Manual (CMS Publication 100-02), Chapter 9External PDF, §20.1 which states, "The attending physician is a doctor of medicine or osteopathy who is legally authorized to practice medicine or surgery by the state in which he or she performs that function, or a nurse practitioner, and is identified by the individual, at the time he or she elects to receive hospice care, as having the most significant role in the determination and delivery of the individual's medical care. A nurse practitioner is defined as a registered nurse who performs such services as legally authorized to perform (in the state in which the services are performed) in accordance with State law (or State regulatory mechanism provided by State law) and who meets training, education, and experience requirements described in 42 CFR 410.75External Website."

      Reviewed: 03.21.17

  2. How do I know where to ask my Medicare questions? Can CGS answer questions about survey issues, such as hospice aide supervision requirements, or patient rights?

    • Medicare, under the administration of the Centers for Medicare & Medicaid Services (CMS), has multiple facets of operations, many of which are run by contracting entities. As a Medicare Administrative Contractor (MAC), CGS's primary role is to process your Medicare claims correctly. In order to do that, we also provide related functions and services such as medical review, education and customer service. CGS is not able to answer questions regarding the Conditions of Participation (CoPs). These questions are handled by each state's survey and certification office. Aide supervision and patient rights issues fall under this area as well. To find your state survey agency office, go to www.cms.gov/apps/contactsExternal Website. For more information about the various entities who contract with CMS to administer the Medicare program, refer to the CMS Medicare Learning Network (MLN) Matters article Special Edition (SE) article #1123External PDF.

      Reviewed: 03.21.17

  3. What are the physician's narrative requirements that are part of the hospice certification/recertification?

    • Regulations for the physician's narrative can be found in the Medicare Benefit Policy Manual (CMS Pub. 100-02), Ch 9 § 20.1External PDF. The narrative must explain the clinical findings that support a life expectancy of 6 months or less. This can either be a part of the certification/recertification forms, or as an addendum to the certification/recertification forms.

      • "If the narrative is part of the certification or recertification form, then the narrative must be located immediately above the physician's signature.
      • If the narrative exists as an addendum to the certification or recertification form, in addition to the physician's signature on the certification or recertification form, the physician must also sign immediately following the narrative in the addendum.
      • The narrative shall include a statement directly above the physician signature attesting that by signing, the physician confirms that he/she composed the narrative based on his/her review of the patient's medical record or, if applicable, his or her examination of the patient. The physician may dictate the narrative.
      • The narrative must reflect the patient's individual clinical circumstances and cannot contain check boxes or standard language used for all patients. The physician must synthesize the patient's comprehensive medical information in order to compose this brief clinical justification narrative."

      Reviewed: 03.21.17

  4. Where can we find guidance regarding signature requirements?
  5. When a hospice patient transfers to another hospice agency, what documentation should the transferring hospice agency (Hospice #1) provide to the receiving hospice agency (Hospice #2)?

    • When a hospice patient transfers to another hospice agency, the beneficiary must file a signed statement with the transferring hospice (Hospice #1) and the receiving hospice (Hospice #2). The statement must include the name of the prior hospice (Hospice #1), the name of the new hospice (Hospice #2), and the date the transfer is to be effective.

      When the beneficiary transfers to another hospice, it does not terminate the beneficiary's current hospice benefit period. Therefore, it is appropriate for Hospice #1 to provide medical record documentation, such as the notice of election, the physician certification statements, and other pertinent documentation, to ensure there is no disruption in the beneficiary's hospice care. For additional information, refer to the Medicare Benefit Policy Manual, Publication 100-09, Chapter 9External PDF, §20.2.1.

      Reviewed: 03.21.17

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