Medicare Benefit Policy Manual (Pub. 100-02), Ch. 8 § 40.1
Who May Sign the Certification or Recertification for Extended
40.1 - Who May Sign the Certification or Recertification for Extended
Care Services
(Rev. 261, Issued: 10-04-19, Effective: 11-05-19, Implementation: 11-05-19)
A certification or recertification statement must be signed by the attending physician or a
physician on the staff of the skilled nursing facility who has knowledge of the case, or by
a physician extender (that is, a nurse practitioner (NP), a clinical nurse specialist (CNS)
or, effective with items and services furnished on or after January 1, 2011, a physician
assistant (PA)) who does not have a direct or indirect employment relationship with the
facility, but who is working in collaboration with the physician.
In this context, the definition of a “direct employment relationship” is set forth in the
regulations at 20 CFR 404.1005, 404.1007, and 404.1009. Under the regulations at 42
CFR 424.20(e)(2)(ii), when a physician extender has a direct employment relationship
with an entity other than the facility, and the employing entity has an agreement with the
facility that includes the provision of general nursing services under the regulations at 42
CFR 409.21, an “indirect employment relationship” exists between the physician
extender and the facility. By contrast, such an indirect employment relationship does not
exist if the agreement between the facility and the physician extender’s employer solely
involves the performance of delegated physician tasks under the regulations at 42 CFR
483.30(e).
Further information regarding certification and recertification of extended care services,
including details on the content of the certification or recertification, timing of
recertifications and the impact of delays on certifications and recertifications, appears in
Pub. 100-01, Medicare General Information, Eligibility, and Entitlement Manual, Chapter
4, “Physician Certification and Recertification of Services,” §§40 - 40.6.