Hospice Reporting Requirements Optional Until April

Hospices should be aware of revised reporting requirements that went into effect Jan. 1. These reporting requirements are optional right now, but they become mandatory April 1. Noncompliance will likely cause delays in claims adjudication.

For notice of elections and claims with effective dates or dates of service on or after Jan. 1, the hospice may begin reporting the National Provider Identifier (NPI) of the attending physician/nurse practitioner (NP) in the “attending physician” field on the Notice of Election (NOE) claim. Effective April 1, this requirement is mandatory.

Note: The NOE should be filed as soon as possible after a patient elects the hospice benefit.

The hospice should enter the NPI and name of the attending physician designated by the patient at the time of election who has the most significant role in the determination and delivery of the patient’s medical care. The hospice physician responsible for certifying that the patient is terminally ill, with a life expectancy of six months or less if the disease runs its normal course, should be reported in the “other physician” field.

Note: Both the attending physician and other physician fields should be completed even if the hospice physician certifying the terminal illness is the same as the attending physician.

An Attending Physician Is …

The code of Federal Regulation, Title 42, section 418.3 defines the “attending physician” as:

  1. Doctor of medicine or osteopathy legally authorized to practice medicine and surgery by the state in which he or she performs that function or action; or nurse practitioner who meets the training, education, and experience requirements as described in section 410.75 (b); and
  2. Is identified by the individual, at the time he or she elects to receive hospice care, as having the most significant role in the determination and delivery of the individual’s medical care.

For complete details, read the Centers for Medicare & Medicaid Services (CMS) Transmittal 1885, CR 6540, issued Dec. 23, 2009.

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