CMS Delays Implementation of the Hospice Certifying Physician Enrollment Requirement

NHPCO

The The May 1 go-live date for the Medicare hospice certifying physician enrollment requirement is delayed until June 3. The Centers for Medicare & Medicaid Services (CMS) notified NHPCO and the National Association for Home Care & Hospice (NAHC) today of this decision and will be making a public announcement soon. This change follows both organizations’ continued engagement with CMS to ensure seamless and appropriate implementation of this requirement.

The hospice physician enrollment requirement was originally set to begin on May 1, as finalized in the Fiscal Year (FY) 2024 Hospice Wage Index final rule. Under this requirement, a physician must be Medicare enrolled or validly opted-out in order to certify a patient’s terminal illness under the Medicare hospice benefit. As previously reported, the implementation of this requirement caused confusion and concern within the hospice community. NAHC and NHPCO have been working together to address the issues and unintended consequences of the requirement, and met with CMS this week to relay these concerns and request the following:

1. Expedient and clear guidance
2. Flexibility in claim processing
3. Part B MAC physician enrollment processing guidance

We thank CMS for its engagement on the issues and the resulting delay in implementation. We expect to see clarified instructions for claims processing and guidance on physician enrollment application processing. We will provide more information as it becomes available. Until then, hospices should continue to implement procedures to ensure that the certifying physician(s) is enrolled in Medicare or validly opted-out.