Beginning May 1, 2024, the Centers for Medicare & Medicaid Services (CMS) will require hospice certifying physicians to either be enrolled in or validly opted-out of the Medicare program to certify hospice services. This requirement applies to both the hospice physician throughout the recertification process and the attending physician (if the patient has one) at the time of initial certification. This requirement does not extend to non-physician practitioners designated as a patient’s attending physician as only physicians can certify a patient’s terminal illness under the Medicare hospice benefit.
If a referring physician is currently enrolled or opted out, they will not need to do anything.
This new requirement:
- Only applies to Fee-for-Service Medicare
- Doesn’t prohibit the patient’s independent attending physician from treating them while in hospice and billing for these services under Part B
- Applies to all written or oral certifications under § 418.22(c)
Hospices can verify a physician’s enrollment or opt-out status using the CMS ordering and referring data file (ORDF), which lists all Medicare-enrolled and opted-out physicians.
This new requirement is part of a medicare program FY2024 final rule released in August 2023.
