Designated Hospice Attending Physicians

Effective January 1, 2019, Medicare beneficiaries electing the hospice benefit can select physician assistants (PAs) as their attending physicians. According to Change Request (CR) 10517 (PDF, 163 KB) physician assistants (PAs) are now “recognized as designated hospice attending physicians, in addition to physicians and nurse practitioners (NPs).” Prior to January 1, 2019, only physicians and nurse practitioners (NPs) were allowed as hospice attending physicians. CR 10517 provides the following updates in the Medicare Benefit Policy Manual (Pub. 100-02, Chapter 9 – Coverage of Hospice Services Under Hospital Insurance) (PDF, 640 KB):

Section 20.1 – Timing and Content of Certification
The designated attending physician must be a medical doctor, osteopathic physician, NP, or PA, who is legally authorized in his/her state to provide hospice services. When electing to receive hospice care, the beneficiary should identify the attending physician. 

Section 20.2.1 – Hospice Election
The beneficiary must clearly identify the attending physician on the election statement and provide enough detail to show whether the attending provider is a physician, NP, or PA. This should include the physician’s full name, office address, NPI number, and any other information necessary to identify the designated physician.

Section 40.1.3.1 – Attending Physician Services
To change a designated attending physician, the beneficiary (or representative) must sign a statement with the hospice facility that clearly identifies the new attending physician. The statement must be signed on or after the effective date of the new physician.

Section 40.1.3.3 – Physician Assistants as Attending Physicians
Medicare will pay for medically necessary hospice services provided to Medicare beneficiaries who select PAs as their attending physicians. The PA must be authorized to perform services in accordance with his/her State law and  be a professional who meets the training, education, and experience described in the Code of Federal Regulations (CFR) at 42 CFR 410.74 (c) (PDF, 182 KB). If beneficiaries do not have attending physicians, they may select physicians, NPs, or PAs who are employed by hospice facilities. Attending PAs cannot:

  • Certify or re-certify terminally ill beneficiaries
  • Perform face-to-face encounters
  • Act as medical directors of hospice facilities
  • Contract with hospice facilities for attending physician services per the Hospice Care; Hospice Program section of the Social Security Act, Section 1861(dd)(2)(B)(i)(III)

Hospice facilities should bill Medicare Part A for PAs who are hospice employees. PAs should bill Medicare Part B if they are not employed by hospice facilities. Medicare can be billed separately for PA services only if:

  • The PA is the beneficiary's designated attending physician
  • Services are medically reasonable and necessary
  • Services would normally be performed by a physician in the absence of the PA
  • Services are not related to the certification of terminal illness

References:

Change Request (CR) 10517 (PDF, 163 KB)
  
Internet Only Manuals — Medicare Benefit Policy Manual (Pub. 100-02, Chapter 9 – Coverage of Hospice Services Under Hospital Insurance) (PDF, 640 KB)

Code of Federal Regulations - 42 CFR 410.74 (c) (PDF, 182 KB)

Social Security Act, Section 1861(dd)(2)(B)(i)(III), Hospice Care; Hospice Program

Billing Hospice Physician, Nurse Practitioner (NP) and Physician Assistant (PA) Services
(Related to Terminal Diagnosis)
(PDF, 240 KB)

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