NHPCO and NAHC Issue Update on Certifying Physician Enrollment Requirements

NHPCO Summary at a Glance

May 1, 2024, a new hospice claims edit will be implemented. This edit, associated with the condition of payment finalized in the Fiscal Year (FY) 2024 Hospice Wage Index final rule, requires that the hospice certifying physician(s) be enrolled in Medicare or have a valid opt-out on file. This has raised many questions and concerns about the implementation of the edit from both hospice providers and Electronic Health Record (EHR) companies due to lack of clarity and conflicting information in instructions and guidance.

Two key points for hospices to know at this time are:

• As long as the Attending Physician field on the claim contains the NPI of a physician that is enrolled or validly opted-out, the edit that goes into effect on May 1 will allow the claim to process and be paid.
  
  
• The edit that goes live on May 1 will only verify the physician listed in the Attending Physician field on the claim. On October 7, 2024, a new edit will go live that will verify the physician listed in the Attending Physician field on the claim and the physician listed in the Referring Physician (Other Physician) field on the claim.

NHPCO and NAHC are working on a Frequently Asked Questions document and plan to publish this in the near future. Any questions can be directed to [email protected].