Hospice Certification / Recertification Requirements
Medicare Benefit Policy Manual (CMS Pub. 100-02), Ch. 9
§20.1
In order for a patient to be eligible for the Medicare
hospice benefit, the patient must be certified as being terminally ill. An individual
is considered to be terminally ill if the medical prognosis is that the
individual’s life expectancy is 6 months or less if the illness runs its normal
course. The certification/recertification is a critical piece of documentation
necessary to ensure Medicare payment for the hospice services you provide.
The hospice must obtain verbal or written certification of
the terminal illness, no later than 2 calendar days (by the end of the third
day) after the start of each benefit period (initial and subsequent). Initial
certifications may be completed up to 15 days before hospice care is elected. Recertifications
may be completed up to 15 days before the start of the next benefit period.
If written certification/recertification cannot be obtained within
2 calendar days, verbal certification must be obtained. The hospice must
determine who may accept verbal certification from a physician in compliance
with state and local law regulations.
In addition, the hospice must ensure the written certification/recertification
is signed and dated prior to billing Medicare, or their claim(s) may be denied.
Content of the Certification/Recertification
The certification should be based on the clinical judgment
of the hospice medical director (or physician member of the interdisciplinary
group (IDG)), and the patient’s attending physician, if he/she has one.
In addition to the initial certification for hospice, the
patient must be recertified for each subsequent hospice benefit period.
The written certification/recertification must include:
The statement that
the patient’s medical prognosis is that their life expectancy is 6 months or
less if the terminal illness runs its normal course
A brief narrative,
written by the certifying physician, explaining the clinical findings that
support the patient’s life expectancy of six months or less. This narrative can
be a part of the certification/recertification form or as an addendum to the
form.
If the
narrative is part of the form, it must be located immediately above the
physician’s signature.
If the
narrative is an addendum, the physician must also sign the addendum immediately
following the narrative.
Do not include
check boxes or standard language used for all patients. The narrative cannot be
completed by other hospice personnel; it must be completed by the certifying
physician.
The narrative
shall include a statement, located above the physician signature and date, that
attests to the fact that by signing the form, the physician confirms that
he/she composed the narrative based on his/her review of the patient’s medical
record or his/her examination of the patient.
The benefit period
dates that the certification or recertification covers.
Effective for
recertifications on/after January 1, 2011, narratives associated with the third
benefit period and subsequent benefit periods must explain why the clinical
findings of the face-to-face encounter support a life expectancy of six months
or less. Documentation must include the date of the encounter, an attestation
by the physician or nurse practitioner that he/she had an encounter with the
beneficiary. If the encounter was done by a nurse practitioner, he/she must
attest that clinical findings were provided to the certifying physician.
Signature Requirements for Certification
Acceptable signatures:
Handwritten
signatures
Electronic
signatures
Facsimile of
original written or electronic signatures
Unacceptable signatures-STAMPS
Stamped
signatures—NOT ACCEPTABLE
Signatures for Initial Certifications:
For the first benefit period after election of the Medicare
hospice benefit, the certification must be signed and dated by the:
Medical director
of the hospice or the physician member of the hospice interdisciplinary group
(IDG); and
The beneficiary’s
attending physician (if they have one).
Note: To sign the certification, the attending physician
must be a doctor of medicine or osteopathy, and be identified by the
beneficiary at the time he/she elects to receive hospice care as having the
most significant role in the determination and delivery of the individual’s
medical care.
Signatures for Recertifications:
For the recertification (for subsequent hospice benefit
periods), only the hospice medical director or the physician member of the IDG
is required to sign and date the certification. The beneficiary’s attending
physician is not required to sign and date the recertification.
Face-to-Face (FTF) Encounter
For recertifications on/after January 1, 2011, a hospice
physician or hospice nurse practitioner must have a face-to-face encounter with
each hospice patient prior to the beginning of the patient’s third benefit
period, and prior to each subsequent benefit period. The FTF must occur within
30 calendar days prior to the start of the 3 rd or later benefit period, unless
exceptional circumstances are met. Examples of exceptional circumstances
include an EMERGENCY WEEKEND PROTOCOL.
Common Hospice Certification Errors
Medicare cannot make appropriate payment without correct
dates, signatures and identifying roles of the physician(s). The following list
identifies the common types of missing and inadequate information:
Predating
physician(s) certification signatures
Not having both the
hospice medical director and attending physician (if applicable) sign the
initial certification as required
The physician
narrative is missing
The attestation
statement is missing
Not having verbal
certifications by both the medical director and attending physician (if
applicable)
No physician(s)
signatures
Illegible
physician signatures
Physician did not
date his/her signature
Not clearly
stating the dates the certification period encompasses
