The role of the attending physician in hospice care has recently become a topic of increased attention and discussion. As part of the hospice election statement, which is required, there must be a section that allows the patient to identify an attending physician in the community if they choose to do so. This designation plays an important role in how care is coordinated and documented throughout the patient’s hospice benefit.
If a patient names an attending physician in the community, the first step for the hospice is to verify that the physician is enrolled in PECOS. This step is mandatory, there is no option to skip it. The hospice must confirm that the physician is either enrolled in PECOS or has formally opted out, meaning they must still be listed within the PECOS system.
If the patient identifies a nurse practitioner or physician assistant, PECOS enrollment is not required. However, if the attending provider is a physician they must be enrolled in PECOS. Because the attending physician must be included on the hospice claim, CMS will verify PECOS enrollment for physicians. If the listed physician is not found in PECOS, the claim will be rejected.
Another hot topic receiving significant attention lately is the attending physician’s role in the certification process. If a patient designates an attending physician in the community who is qualified to certify hospice eligibility, and the patient is entering their very first 90-day hospice benefit period, the hospice is required to obtain a certification from that attending physician for that initial 90-day period.
If the hospice accepts a verbal certification during the initial two-day window rather than a written, signed certification, a verbal certification must also be obtained from the attending physician. This means the hospice must receive a verbal certification from both the attending physician and the hospice medical director or certifying physician. Afterward, the hospice must secure a written and signed certification, also known as the Certificate of Terminal Illness, from both the attending physician and the hospice physician.
Some hospices obtain the Certificate of Terminal Illness (CTI) from their hospice physician and then send that document to the attending physician in the community to obtain their signature or co-signature. This approach is acceptable, but both certifications are still required.
Therefore, if you obtain a verbal certification from your hospice physician and later secure the written certification, you must follow the same process with the attending physician by obtaining both the verbal certification and the written signature from them as well.
Again, this requirement only applies if the attending physician named in the community is a qualifying certifying practitioner. If the patient designates a nurse practitioner or physician assistant as the attending provider, they do not need to be involved in the hospice certification documentation.
It is very important to understand that the attending physician must be listed on the hospice claim. If the attending provider is a physician (such as an MD or DO) and not a nurse practitioner or physician assistant, they must be enrolled in PECOS.
Additionally, when a patient has a designated attending physician, that provider should be involved in the patient’s care during the hospice stay. While they are not required to attend interdisciplinary group (IDG) meetings, the documentation should reflect participation in the patient’s care.
If the attending physician is not participating in the patient’s hospice care or refuses to do so, the hospice is required to notify the patient that their chosen attending physician in the community is declining to participate. The patient must then be given the option to select a different attending physician.
If the patient chooses to change to another community physician, they must complete a Change of Physician or Attending Physician form and provide their signature. The effective date of the change will be the date they sign the form.
HPS hospice consultants are available and ready to assist with any of your hospice-related needs. If you have any questions, please feel free to reach out to us.
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