CMS has issued Transmittal 205/Change Request (CR) 9114, which makes changes to Chapter 9 of the Medicare Benefit Policy Manual to reflect regulatory changes put into effect as part of the FY 2015 payment rule. CR 9114 revises the manual and provides explicit sections related to the notice of election (NOE), hospice revocation, hospice discharge, and hospice notice of termination or revocation (NOTR), and also expands the existing section on attending physician services. These changes will take effect on May 4, 2015.
“However, it is important to note that CMS has included a new requirement that — as part of the information identifying the attending physician on the election statement — the hospice must include the physician’s national provider identifier (NPI) number. This is a change from the information CMS included in the final FY2015 payment regulations in that the NPI was referenced as a potential item for identifying the attending physician on the election statement but not explicitly required. The National Association for Home Care & Hospice (NAHC) has concerns that hospices may not have access to the NPI of the attending physician at the time the election statement is signed and that patients may have some concerns about signing a form with empty spaces on it. One option may be to include space for the attending’s NPI in a FOR OFFICE USE ONLY box on the form. NAHC has sought guidance from CMS on this issue, and also as to whether it is appropriate for the hospice to enter the attending physician’s NPI on the form after it has been signed. We will provide any guidance that we receive from CMS in future publications. In the meantime, hospices and vendors are advised to modify their election statements to include space for the NPI of the patient’s chosen attending physician, as well as to educate staff and modify processes to ensure that the NPI of the attending physician is secured and entered onto the election statement in time for the May 4, 2015, effective date. NAHC has also sought additional clarification from CMS regarding requirements related to designation of attending physician for purposes of the hospice benefit and is awaiting response.”
Click here for more details from NAHC.