Hospice Billing

Hospice Claim Reporting Requirements for Attending and Certifying Physicians

​​​​Under CMS' current guidelines, the hospice medical director or the hospice physician and the attending physician (if the beneficiary has one), must initially certify the patient’s terminal condition. The guidance in CR 13342 is letting providers know the claims system will now be editing for the physician NPIs reported on the claim. CMS is making sure certifying physicians, including hospice physicians and hospice attending physicians, are enrolled in or opted-out of Medicare before paying for their hospice services. The hospice physician and attending physician need to be enrolled/opted-out at the time they make the certification or recertification of hospice care for a patient.

The implementation of CR 13531 on 10/7/2024 changes and implements additional edits on hospice claims for certifying/recertifying physician Medicare enrollments for all hospice claims received on or after 10/7/2024 with a "From" date on or after 6/3/2024. The hospice certifying physician edits do not apply to claims with "From" dates prior to 6/3/2024.

  • FISS will look at the physician information reported on hospice claims and compare the name and NPI reported to PECOS
  • If the physician is not in the PECOS hospice ordering and referring files, the claim will edit for reason code 17729.

Effective on initial certifications for claims submitted prior to 10/7/2024 with dates of service 6/3/2024 or later:

  • FISS will check the REF PHYS NPI field and the ATT PHYS NPI field on hospice claims for initial certifications to make sure the certifying physicians, including hospice physicians and hospice attending physicians, are enrolled in or opted-out of Medicare.
  • Report the name and NPI of the certifying physician in the REF PHYS field
  • Report the name and NPI of the attending physician in the ATT PHYS field (if the patient has chosen one)
  • If the certifying and attending physician are the same, only report the name and NPI of the physician in the ATT PHYS field

Effective on subsequent certifications for claims submitted prior to 10/7/2024 with dates of service 6/3/2024 or later:

  • Report the name and NPI of the certifying physician in the ATT PHYS field
  • Leave the REF PHYS field blank to avoid the 17729 edit

For all claim submissions on or after 10/7/2024, with dates of service 6/3/2024, or later:

  • Report the name and NPI of the attending physician designated by the patient in the ATT PHYS field
    • If the patient has not chosen an attending physician, enter the certifying/recertifying physician in this field
    • The patient's designated attending physician can be an independent physician, hospice physician, nurse practitioner, or physician assistant
      • NPs or PAs will be bypassed for editing
  • Report the name and NPI of the certifying physician in the REF PHYS field
    • When the attending physician is also the certifying/recertifying physician, only populate the ATT PHYS field

Edits will only apply to both fields if both the ATT PHYS and REF PHYS fields are completed.

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Revised 9/27/2024