On October 1, 2014, CMS revised its attending physician requirements, setting another potential trap for the unwary. 42 C.F.R. 418.24 [Election of Hospice].
While statute and regulation have long required both the attending physician and hospice medical director to certify initial eligibility, CMS has now tightened regulation around identification and change of attending physician. The natural result of this change will be a more stressful hospice election process for new patients and increased audit risk for hospices.