Updates From CMS 2019-2020

• Change to Medicare Patient Access to Hospice Act to include PAs as "Hospice Attendings"
• Specifically supported PAs as members of the Hospice Interdisciplinary Team
• 2020: Clarified and revised § 418.106(b)(1) to permit a hospice to accept drug orders from a physician, NP, or PA

November 2020 CMS released the final CY 2020 Medicare Physician Fee Schedule which again acknowledged that as elected “attending physicians” for patients on hospice, PAs can order medications while serving as the patient’s attending physician, as long as they are acting within the state scope of practice requirements and hospice policy. 

In effect, what CMS says we can do for now:

• As a hospice attending, just like MDs and NPs, PAs will be able to be the one provider that that patient can see, along with the hospice team
• PAs will be part of the hospice interdisciplinary care team and can provide guidance
• PAs will be able to order equipment and services for them
• Hospice to accept drug orders from a physician, NP, or PA

What CMS says we cannot do for now:

• PAs cannot be directly employed by a hospice AND serve as a patient’s hospice attending
• PAs and NPs cannot certify for terminal illness
• PAs cannot do the re-certification visits, "face-to-face" visits that hospices employ NPs and MDs to do

Also, PAs still need to follow their own State’s laws and statutes regarding hospice care and PAs, which may not yet recognize us as hospice attendings and/or hospice prescribers. 

For questions regarding restrictive hospice language in your state, you can contact Erika Miller at emiller@aapa.org as noted in the link below.  You may also try reaching out to your state's hospice association--many states have one.  

See the AAPA page with Hospice FAQs.

Keep an eye out on this space for updates and further guidance!

PAHPM, and many of our hospice partners, feels that PAs should be able to be directly employed by hospice.  They recognize the value of PAs on the hospice interdisciplinary team and CMS acknowledged this from the comments they received on their ruling.  Many also feel that PAs, like our nurse practitioner colleagues, should be able to participate in the recertification process for hospice which we currently are unable to do.  We are already in discussion with our Coalition partners and AAPA as to how we can further work with CMS and Congress to update the Hospice Act and rules relating to it to reflect the modern-day role of Advance Practice Providers (APPs) in our patients’ care.

Still Confused?

I know I was!

I've recorded a PowerPoint video that I've presented before that I hope clears it up!

The audience was for hospice and palliative care organizations, and I think it will help you too!

--Jeff Myers, PA-C

April 2022

The Role of PAs in Hospice & Palliative Care