With new regulations around alternatives to social workers in the hospice interdisciplinary group (IDG), CMS has offered new guidance to state surveyors in Appendix M.
The 2024 Physician Fee Schedule final rule, published Nov. 16, 2023, included an update to IDG requirements, adding marriage and family therapist (MFT) or mental health counselor (MHC) as alternatives to a social worker on the IDG.
The guidance is around citation code L541 for the make-up and involvment of the IDG. According to the Quality, Certification & Oversight Reports, there were 58 citations fro L541 from October 2021 through August 2023 — the most recent data available. Generally citations focused on a review of IDG documentation that suggested a lack of involvment from some IDG members.
The associated interpretive guidelines, which remain unchanged, note: The number of individuals on the IDG is not as important as their qualifications and abilities. For example, if a group member meets the hospice criteria and is licensed as a RN and also meets the Medicare criteria to be considered a social worker under the hospice benefit, he/she would be qualified to serve on the IDG as both a nurse and a social worker