Center to Advance Palliative Care

You are quite right that you should be billing part B for non-hospice palliative care services. However, before you get to that point, you will want to review State regulations (is hospice allowed to provide non-hospice services in your State?) and Corporate Practice of Medicine considerations. Consultation on these issues with a health care attorny familiar with the laws and regulations of your State is a good idea. You will also want to determine the organizational structure of your program - is it a separate corporate entity or a program of your hospice - either will work and there are advantages and disadvantages to both.

As you suspect, part of the confusion stems from the fact that as a hospice, you are a Part A biller; using the name 'hospice' to bill for Part B palliative care services has caused confusion elsewhere.

To bill Part B, you will need a supplier number from Medicare; you will also need to submit completed provider Part B enrollment applications and each provider will need to have a National Provider Identification Number.

I suggest you contact Janet Braun (JBraun@hospicebg.org) Hospice of the Bluegrass which is one of the CAPC Palliative Care Leadership Centers. The palliative care billing staff at Bluegrass is excellent and has successfully addressed the issues you are confronting.

Let us know how you do - and if you have any further questions.

Amber B. Jones, MEd
Hospice Liaison Consultant
Center to Advance Palliative Care