Home Health & Hospice Week

Hospices can make sure they're using nurse practitioners to the best of their abilities by checking out new guidance on NPs' role in the Medicare hospice benefit.

A new program memorandum and hospice manual revision from the Centers for Medicare & Medicaid Services spells out that NPs can "see, treat and write orders for patients" if state law permits it. And nothing precludes a hospice from employing an NP, the memo adds.

Allowing NPs to write orders and visit hospice patients may come as news to many hospices, says Janet Neigh of the Hospice Association of America. "CMS says this is not new," Neigh tells Eli. The agency just hasn't "spelled it out before."

The guidance, in June 20 memo A-03-053 and Transmittal No. 68, doesn't break new ground but does clarify NPs' role in Medicare hospice, notes Judi Lund Person with the National Hospice and Palliative Care Organization.

Written Guidance Encourages NP Use

Hospices that were hesitant to allow NPs that wide a role in hospice without written documentation should be encouraged by the new guidelines to use the clinicians more fully, says hospice consultant John Mahoney with Penfield, NJ-based Summit Business Group.

NPs can perform those duties only where state law permits it, Neigh reminds hospices. The memo specifies that "the services provided by the NP would include those recognized and accepted by the State in which the services are provided and which are not excluded by Federal regulation."

"In addition the NP role and responsibilities would need to be defined in the beneficiary's plan of care," the memo adds.

While the clarification is helpful, it doesn't go far enough in widening NPs' role in the benefit, Person contends. Medicare regulations still don't allow NPs to certify or recertify patients' six-month diagnoses for the hospice benefit, independently establish or update the plan of care, fulfill the physician's role in the interdisciplinary group, serve as a patient's attending physician or bill for any of those services, the memo and manual spell out.

Hospices want a greater role for NPs than Medicare laws allow, Mahoney points out. For example, when an NP is already serving as a patient's attending physician and the patient then elects hospice, the NP should be able to continue in that role, Neigh maintains.

Hospices don't particularly want NPs to certify or recert patients' six-month diagnoses, Person explains. But they do want NPs to be able to establish and update the POC and bill for those services.

The industry has to pursue those goals through legislation, she adds.

Editor's Note: The memo is at www.cms.gov/manuals/pm_trans/A03053.pdf and the manual revision is at www.cms.gov/manuals/pm_trans/R68HSP.pdf.