Home Health & Hospice Week

Get used to checking the ordering and referring data file often.

When hospices got a seven-month reprieve last year on the tightening of enrollment requirements for physicians certifying hospice patients, that was great news. But the time has come to deal with the new requirement.

Reminder: In last year’s hospice final rule issued in July 2023, the Centers for Medicare & Medicaid Services adopted a requirement that two categories of physicians must be enrolled in or validly opted out of Medicare for hospice services to be paid: the hospice medical director or the physician member of the hospice interdisciplinary group; and the attending physician, if the beneficiary has one (see HHHW by AAPC, Vol. XXXII, No. 28). But CMS granted hospices’ requests for an implementation delay, putting off the date until May 1, 2024.

Now that date is right around the corner, and hospices are scrambling to understand and comply with the new mandate.

In CMS’ April 5 Open Door Forum for home health and hospice providers, multiple providers asked questions about how the requirement will work.

For example: One provider told CMS that one of their certifying docs was on the valid opt-out list, but didn’t appear in Medicare’s ordering and referring data file (ORDF). Another attendee asked if it was OK that a nurse practitioner or physician assistant acting as an attending didn’t appear in the file.

CMS didn’t answer most of the questions, instead requesting more information and pointing hospices to the transmittal communicating the changes.

CMS officials did, however, point out that the ORDF is updated twice a week, so hospices should keep tabs on their physicians’ statuses.

Multiple attendees told CMS that they would like the ORDF to indicate when a physician’s enrollment is set to expire or if it is in the approval process. Currently the file does not provide that information.

Note: Details of the requirement are in Change Request 13342 at www.cms.gov/files/document/r12330otn.pdf. The ORDF is at https://data.cms.gov/provider-characteristics/medicare-provider-supplier-enrollment/order-and-referring/data — scroll to the right for the hospice column.