NAHC, NHPCO Comment on Revision of Hospice Certifying Physician Enrollment Requirement

WASHINGTON & ALEXANDRIA, Virginia—The National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO) responded to the Centers for Medicare & Medicaid Services (CMS) recently revised guidance regarding the implementation of the hospice certifying physician enrollment requirement.

NAHC and NHPCO identified that some instruction provided by CMS was inconsistent with established law and regulations regarding the certification of a patient’s terminal illness for new hospice elections after the first benefit period. That instruction, if implemented, could have resulted in major negative impacts on hospices and the patients and families they serve. Both organizations requested that CMS retract the guidance to remain consistent with regulation and statute. On June 6, CMS rescinded its guidance in order to align with current regulations, offering clarity for providers.

“This retraction is a direct result of NAHC and NHPCO’s ongoing engagement with the agency and represents a critical win for providers in avoiding undue regulatory and administrative burdens,” said the two organizations in a press release. 

This follows CMS’s previous delay of the requirement from May 1 to June 3, in response to concerns raised by NAHC and NHPCO.

“NAHC supports the reasons for the certifying physician enrollment requirement and appreciates CMS’s ongoing engagement on the implementation of the claims processing edits for this requirement,” said NAHC President William A. Dombi. “We thank CMS for rescinding the instruction that was not consistent with statute and regulation and had spurred many questions and concerns from hospices. This has alleviated confusion in the industry and avoids disruptive negative impacts.”

“We thank CMS for its engagement and partnership on this issue,” said NHPCO COO and Interim CEO for NHPCO Ben Marcantonio. “Considering the staffing constraints many providers currently face, this clarification frees up both operational and physician resources to be best allocated to delivering the highest-quality care to patients and families.”

NAHC and NHPCO will continue to work closely with CMS to gain further clarification around remaining inconsistencies in the claim completion guidelines.