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Press Release | Advocacy, Hospice

NAHC & NHPCO Joint Statement: CMS Revises Guidance on Implementation of Hospice Certifying Physician Enrollment Requirement

June 7, 2024

Washington, DC and Alexandria, VA) – The National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO) responded to the Centers for Medicare & Medicaid Services (CMS) recently revised guidance regarding the implementation of the hospice certifying physician enrollment requirement.

NAHC and NHPCO identified that some instruction provided by CMS was inconsistent with established law and regulations regarding the certification of a patient’s terminal illness for new hospice elections after the first benefit period. That instruction, if implemented, could have resulted in major negative impacts on hospices and the patients and families they serve. Both organizations requested that CMS retract the guidance to remain consistent with regulation and statute. On June 6, CMS rescinded its guidance in order to align with current regulation, offering clarity for providers.

This retraction is a direct result of NAHC and NHPCO’s ongoing engagement with the agency and represents a critical win for providers in avoiding undue regulatory and administrative burdens. This follows CMS’ previous delay of the requirement from May 1 to June 3, in response to concerns raised by NAHC and NHPCO.

“NAHC supports the reasons for the certifying physician enrollment requirement and appreciates CMS’ ongoing engagement on the implementation of the claims processing edits for this requirement,” said NAHC President William A. Dombi. “We thank CMS for rescinding the instruction that was not consistent with statute and regulation and had spurred many questions and concerns from hospices.  This has alleviated confusion in the industry and avoids disruptive negative impacts.”

“We thank CMS for its engagement and partnership on this issue,” said NHPCO COO and Interim CEO for NHPCO Ben Marcantonio. “Considering the staffing constraints many providers currently face, this clarification frees up both operational and physician resources to be best allocated to delivering the highest-quality care to patients and families.”

NAHC and NHPCO will continue to work closely with CMS to gain further clarification around remaining inconsistencies in the claim completion guidelines.

Press Contact:

  • Thomas Threlkeld, Director of Communications
  • // 202-547-7424


About National Association for Home Care & Hospice (NAHC)

The National Association for Home Care & Hospice (NAHC) is the voice of home care and hospice. NAHC represents the nation’s 33,000 home care and hospice providers, along with the more than two million nurses, therapists, and aides they employ. These caregivers provide vital services to Americans who are aged, disabled, and ill. Some 12 million patients depend on home care and hospice providers, who depend on NAHC for the best in advocacy, education, and information. NAHC is a nonprofit organization that helps its members maintain the highest standards of care. To learn more, visit


The National Hospice and Palliative Care Organization (NHPCO) is the nation’s largest and oldest membership association for providers who care for people affected by serious and life-limiting illness. Our members deliver and expand access to high-quality, person-centered interdisciplinary care to millions of Americans. NHPCO provides education and resources to support that mission. Together with our advocacy partner, the Hospice Action Network (HAN), we serve as the leading voice advancing public policy to improve serious-illness and end-of-life care, while our CaringInfo program provides free resources to educate and empower patients and caregivers.