Tip of the Month
The NHPCO Regulatory Team has fielded multiple questions
in recent months concerning nurse practitioners (NP), so let's
review the regulations that define their role.
Serving as Attending Physician
An NP may serve as a patient's chosen attending physician
(Section 408/Medicare Prescription Drug Improvement and
Modernization Act of 2003) and may write and sign physician
orders and prescribe medications as their state Nurse Practice Act
allows. An NP who serves in this role may be an employee of the
hospice or may be associated with a community physician practice.
While NPs may serve as attending physicians, they may not
certify or recertify a patient's terminal illness.
Participating in the IDG
An NP who serves as an attending physician should
participate in meetings of the interdisciplinary group (IDG)
where the patient's plan of care is established and updated.
However, the NP may not represent or replace the hospice
medical director or physician designee in the IDG.
Completing the Face-to-face Encounter
The face-to-face encounter may be completed by an NP if he
or she meets the CMS definition of an employee. In the case of
hospices which are subdivisions of larger organizations (such
as a health system), this includes NPs who are assigned to the
hospice as a hospice employee.
The NP must sign and date a written statement attesting
that he or she held a face-to-face encounter with the patient
(specifying the date the visit took place), and that the clinical
findings were provided to the certifying physician.
The NP should also ensure that any clinical findings from the
visit be communicated back to the IDG for use in coordinating
the patient's care.
CMS Medicare Benefit Policy Manual, Chapter 9
(Coverage of Hospice Services Under Hospital Insurance)
Table of Contents for the Digital Edition of NHPCO NewsLine February 2014