CMS to Reissue Change Request 9114 Pertaining to Attending Physician Designation
Forthcoming Reissuance a Result of Questions and Concerns Raised by NAHC and Industry
April 21, 2015 08:09 AM
On Friday, April 17, the National Association for Home Care & Hospice received notification from staff at the Centers for Medicare & Medicaid Services (CMS) that, in response to the many concerns and questions that have been raised by NAHC and the industry about the requirement that hospices include the name and National Provider Identifier (NPI) number of the attending physician on the patient's election statement, CMS plans to reissue Change Request (CR) 9114. NAHC expressed numerous concerns to CMS about the original language and sought clarification after it was released.
The effective result will be that CMS will change the language included in the manual regarding the designation of the attending physician from the previously issued language to revised language.
The following is the previously issued language to be revised:
“Information identifying the attending physician recorded on the election statement should provide enough detail so that it is clear which physician or Nurse Practitioner (NP) was designated as the attending physician. This must include, but is not limited to, the attending physician's name and NPI number."
Here is the revised language:
“Information identifying the attending physician recorded on the election statement should provide enough detail so that it is clear which physician or Nurse Practitioner (NP) was designated as the attending physician. This information should include, but is not limited to, the attending physician's full name, office address, NPI number, or any other detailed information to clearly identify the attending physician.”
Through follow-up discussion with CMS upon receiving notification of the imminent reissuance, NAHC’s understanding is that the NPI is NOT a requirement. However, hospices are reminded that the attending physician-related information on the election statement should be sufficient to provide clear identification of the physician or NP that has been designated by the patient.
This modification to CR 9114 and to the Benefit Policy Manual means that there has been no change in the requirement for designation of the attending physician on the election statement since the new regulation went into effect on Oct. 1, 2014.
According to information NAHC received on Friday, CMS intends to reissue CR 9114 in the very near future. Please stay tuned to NAHC Report for additional information on this and other hospice-related issues.