Hospice Certification / Recertification Requirements

Medicare Benefit Policy Manual (CMS Pub. 100-02, Ch. 9 §20.1)

Physician certification / recertification that the beneficiary meets the hospice criteria of a terminal prognosis is at the core of the hospice benefit.  The written certification / recertification must include:

• A brief narrative, written by the certifying physician, explaining the clinical findings that support a patient’s life expectancy of six months or less if the terminal illness runs its normal course. 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 before 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 under the physician signature, 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.
• Specific clinical findings and other documentation supporting a life expectancy of six months or less; and

Timeframe and Signature Requirements for hospice certifications / recertifications follow.

Common Hospice Certification Errors

Sample Hospice Certification Form

Timeframe for Certification

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 any subsequent).  Initial certifications may be completed up to 2 weeks before hospice care is elected.

If written certification 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. 
The hospice must ensure the written certification is signed prior to billing Medicare, or their claim may be denied.

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Signature Requirements for Certification

Medicare Benefit Policy Manual (CMS Pub. 100-02, Ch. 9 §20.1)

Medicare Program Integrity Manual (CMS Pub. 100-08, Ch 3 §3.4.1.1 B)

Initial Certification:

For the first initial benefit period of hospice coverage, the certification must be signed by the medical director of the hospice or the physician member of the hospice interdisciplinary group and the beneficiary’s attending physician (if the beneficiary has an attending physician.)

• To sign, the attending physician must be a doctor of medicine or osteopathy and be identified by the beneficiary at the time he or she elects to receive hospice care as having the most significant role in the determination and delivery of the individual’s medical care. Hand written, electronic signatures or facsimile of original written or electronic signatures of the physician(s) are acceptable.  Stamped signatures are not acceptable.

Note: Nurse practitioners can act as an attending physician, but cannot sign certifications

Recertification:

For the recertification (for subsequent hospice benefit periods), only the hospice medical director, or the physician member of the hospice interdisciplinary group is required to sign the certification.  The beneficiary’s attending physician is not required to sign.

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Page last updated: July 12, 2010

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