Center to Advance Palliative Care

We have a Palliative Medicine & Medical Ethics department as well as a Hospice department within our organization. They are separate departments (different department numbers/budgets). We have two physicians who are employed in both departments and one physician who is employed only in the Palliative Medicine department. One of the physicians is the Medical Director of BOTH departments. There has been a concern voiced regarding appropriate billing when the physicians who are employed by both departments see a patient through the Palliative Medicine service. The concern is when the referring physicians enter a consult request in the EMR for a palliative medicine consult and the pall med physician sees the patient and discusses/recommends hospice, we submit charges for their services through the Pall Med department (phys services,medicare part B); however, the Pall Med/hospice physician will then in his documentation state “pt/family will decide on hospice services and will meet tomorrow”. The following day the family elects hospice services and the Pall Med/hospice physician will enter a “hospice” consult into the electronic medical record. The concern is, since the physician is also employed by hospice, should they be entering hospice consults or should it be the attending? Could this be viewed as self -referral by Medicare? Would the appropriate manner be for the physicians who are employed by both departments on these cases be billing pre-hospice services? We are not concerned with the physician who is NOT employed by the hospice as there should be absolutely no conflicts with that physician requesting hospice consults. I apologize for the length of this question, but wanted to ensure I provided pertinent information. Thanks.