This week, the Centers for Medicare & Medicaid Services (CMS) Region V, which includes Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin, shared clarification on an ongoing question regarding the roles of hospice medical directors and other hospice physicians.
CMS has agreed that:
The following clarification was shared by the Ohio Department of Health, which it received from the CMS regional office:
By definition a hospice has “A” Medical Director. He or she is assumes responsibility for the entire hospice medical component to include all multi-locations [418.100(2)(f)] and [418.64(A)(1)]. It is permitted that a Medical Director “physician designee” be identified when the Medical Director is away (e.g. vacation, illness) [418.3]. (This is a short-term temporary designee that can be filled by a physician member of the hospice). There should be only one Medical Director. The job description of the Medical Director should differ from other physicians of the IDG.
The hospice regulations support a reading that a hospice organization may only have one physician designee assigned to assume the responsibilities and obligations of the Medical Director when he or she is not available. The expectation is the designee be in place in a situation of leave away from the Hospice organization and not because of geographical concerns.
Additionally the Medical Director is involved in the certification of terminal illness which may also be done with another hospice physician member of the IDG [418.22(5)(i)]. The Medical Director may or may not participate in the IDG or multiples thereof if necessary. Each IDG is required to have a physician member as part of the team to provide coordination of care. [418.56(2)].
As long as the job description indicates the Medical Director is the provider of supervision to the physician member of the IDG, those physicians may also conduct initial and recertification.
To read NHPCO’s full memo on the topic, click here.