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CMS Allowing Hospices to Accept Medication Orders from Some Physician Assistants

Posted on Monday, November 11, 2019 1:43 PM

The new final rule physician pay schedule was posted last week, and it included a long-awaited change for hospices.  CMS is revising §418.106(b)(1) to permit a hospice to accept drug orders from a physician, NP (nurse practitioner), or PA (physician assistant).  The PA must be an individual acting within his or her state scope of practice requirements and hospice policy, and the PA must be the patient’s attending physician, and he or she may not have an employment or contractual arrangement with the hospice.

CMS is asking for comments regarding this new change.  They are looking for comments on:

  • What is the role of a NPP [non-physician practitioner] in delivering safe and effective hospice care to patients? What duties should they perform? What is their role within the hospice interdisciplinary group and how is it distinct from the role of the physician, nurse, social work, and counseling members of the group?
  • Nursing services are a required core service within the Hospice benefit, as provided in section 1861(dd)(B)(i) of the Act, which resulted in the defined role for NPs in the Hospice COPs. Should other NPPs also be considered core services on par with NP services? If not, how should other NPP services be classified?
  • In light of diverse existing state supervision requirements, how should NPP services be supervised? Should this responsibility be part of the role of the hospice medical director or other physicians employed by or under contract with the hospice? What constitutes adequate supervision, particularly when the NPP and supervising physician are located in different offices, such as hospice multiple locations?
  • What requirements and time frames currently exist at the state level for physician cosignatures of NPP orders? Are these existing requirements appropriate for the hospice clinical record? If not, what requirements are appropriate for the hospice clinical record?
  • What are the essential personnel requirements for PAs and other NPPs?

Source: NAHC Report

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