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In 2019 we were encouraged by the changes to the Medicare Patient Access to Hospice Act as part of the Bipartisan Budget Act of 2018 and, subsequently, in CMS regulation as a part of the FY2019 Hospice Wage Index final rule, which broadened the Medicare definition of hospice “attending physician” at 42 CFR ยง418.3 to include PAs.  


In January of 2019, for the first time, CMS and Medicare agreed to recognize PAs caring for patient’s at the end-of-life by reimbursing us as hospice “attendings” for those patient who choose to continue to have their trusted PA to continue the quality care as a PCP or specialist through to the end-of-life on hospice.  The change did not allow PAs to prescribe for patients’ terminal needs and related medication orders, however. Therefore, PAHPM continued to work with our partners within the National Coalition for Hospice and Palliative Care (NHPCO) as well as members of the advocacy and legislative team at AAPA to work with CMS to update the dated rules and conditions of participation of the Hospice Act to reflect the important role PAs have in providing quality care and continuity for our patients through serious illness to the end-of-life.  After widespread support from many, including many PAs sharing their own stories and roles, CMS heard and in November 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, this allows those of us caring for patients with serious illness to continue to follow our patients onto hospice and partner with the hospice to provide care.  CMS ruled that PAs, however, still cannot be employed by hospice directly, and acknowledged that this is something that will need to be addressed by Congress.


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. 


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.

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!

More work to do!


Do you need resources on how to care for patients on Hospice?

Visit some of these resources here.   Members, more to come on this website!