Medicare Benefit Policy Manual (Pub. 100-02), Ch. 9 § 40.1.3
Physicians' Services
40.1.3 - Physicians' Services
(Rev. 188, Issued: 05-01-14; Effective: 08-04-14; Implementation: 08-04-14)
A physician must perform physicians' services (as defined in 42 CFR 410.20(b)(1)(1)),
except that the services of the hospice medical director or the physician member of the
interdisciplinary group must be performed by a doctor of medicine or osteopathy. Nurse
practitioners may not serve as a medical director or as the physician member of the
interdisciplinary group. Nurse practitioners may not bill for medical services other than
those described in 40.1.3.2.
The hospice face-to-face encounter is an administrative requirement related to certifying
the terminal illness as required in §1814(a)(7)(D)(i) of the Social Security Act (the Act).
By itself, it is not billable, as it is considered administrative (see Pub. 100-04, Medicare
Claims Processing Manual, chapter 11, §40.1.1). However, if a hospice physician, or a
hospice nurse practitioner who is also the patient’s attending physician, provides
reasonable and necessary non-administrative patient care during the face-to-face visit,
that portion of the visit would be billable. See section 40.1.3.2 below for additional
requirements for billing physician services provided by NPs.