The Centers for Medicare & Medicaid Services (CMS) released a Frequently Asked Questions (FAQ) document regarding the PECOS enrollment requirement for certifying Hospice physicians, effective June 3. This document clarified important details that must be understood about your claims processing.

Previously and moving forward, if a Hospice patient chooses an Attending Physician in the community as their Attending Physician, that physician or non-physician practitioner (such as a nurse practitioner or PA) should be listed on the claim as the Attending Physician. The Hospice medical director or physician member of the IDG should be listed in the “Other Physician” category.

Under the new PECOS requirement for claims processing with dates of service starting June 3 and forward, a Nurse Practitioner or PA cannot be listed as the Attending Physician on the claim. If they are, the claim will be rejected.

The frequently asked questions document instructs that if a patient has named a Nurse Practitioner or PA as their Attending Physician, they should be listed in the “Other Physician” category, and the Hospice Certifying Physician should be included in the “Attending Physician” box. Alternatively, you may choose to omit the NP or PA from the claim entirely. This policy will be in effect from June 3 through October 6, 2024.

Starting October 7, 2024, you will again be able to list a Nurse Practitioner or PA in the “Attending Physician” box on claims, including those with service dates from June 3 onward. The system will bypass the PECOS edit for the Attending Physician and validate the Hospice Certifying Physician listed in the “Other Physician” category in PECOS.

It is crucial to remember that any attending physician in the community must be enrolled in PECOS. This requirement applies to physicians, but Nurse Practitioners and PAs are excluded. Additionally, all Hospice Physicians who can certify a patient must either be enrolled in PECOS or have opted out.

The opt-out option is generally used by physicians in special situations, such as VA physicians who do not normally bill Medicare. By completing the necessary forms to opt out of billing Medicare, they are entered into the PECOS system.

Should you have any questions regarding this billing update, or if require assistance with your Hospice Billing, please feel free to reach out to us.

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