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March 11, 2020

Hospice Certification of Terminal Illness Resources

For a patient to be eligible for the Medicare hospice benefit, the patient must be certified as being terminally ill. The certification/recertification is a critical piece of documentation necessary for Medicare payment for the hospice services you provide. A common reason for hospice certification errors are related to a missing or invalid physician narrative statement. In regard to the physician narrative, the certification/recertification must include:

  • The statement that the patient's medical prognosis is that their life expectancy is 6 months or less if the terminal illness runs its normal course
  • A brief narrative, written by the certifying physician, explaining the clinical findings that support the patient's life expectancy of six months or less. This narrative can be a part of the certification/recertification form or as an addendum to the form.
  • If the narrative is part of the form, it must be located immediately above the physician's signature.
  • If the narrative is an addendum, the physician must also sign the addendum immediately following the narrative.
  • Do not include check boxes or standard language used for all patients. The narrative cannot be completed by other hospice personnel; it must be completed by the certifying physician.
  • The narrative shall include a statement, located above the physician signature and date, that attests to the fact that by signing the form, the physician confirms that he/she composed the narrative based on his/her review of the patient's medical record or his/her examination of the patient.
  • The benefit period dates that the certification or recertification covers.
  • Effective for recertifications on/after January 1, 2011, narratives associated with the third benefit period and subsequent benefit periods must explain why the clinical findings of the face-to-face encounter support a life expectancy of six months or less. Documentation must include the date of the encounter, an attestation by the physician or nurse practitioner that he/she had an encounter with the beneficiary. If the encounter was done by a nurse practitioner, he/she must attest that clinical findings were provided to the certifying physician.

Other common certification errors include:

  • Predating physician(s) certification signatures
  • Not having both the hospice medical director and attending physician (if applicable) sign the initial certification as required
  • Not having verbal certifications by both the medical director and attending physician (if applicable)
  • No physician(s) signatures
  • Illegible physician signatures
  • Physician did not date his/her signature
  • Not clearly stating the dates the certification period encompasses
  • Narrative missing and/or incomplete information and or illegible

CGS and the Centers for Medicare & Medicaid Services (CMS) provides a variety of resources to help prevent these common errors. Please share the following resources with your clinical staff.


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