DME, Home Health and Hospice: What an NP Can Certify Alone

Which of the three can an NP sign alone?

Two of the three, and the split is written into the definitions rather than left to local custom. Medicare's DMEPOS rule counts a nurse practitioner as a treating practitioner who may write the order 1Ref 1Centers for Medicare & Medicaid Services (HHS) (2026).§ 410.38 Durable medical equipment, prosthetics, orthotics and supplies (DMEPOS): Scope and conditions..That the DMEPOS rule defines the ordering role as treating practitioner and includes a nurse practitioner in it, that every DMEPOS item needs a written order with six elements including the treating practitioner's name or NPI and signature, the split between orders due before delivery and orders due before claim submission, and the six-month face-to-face requirement for power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.. The home health rule counts one as an allowed practitioner who may certify and recertify eligibility 2Ref 2Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.22 Requirements for home health services..That Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, the five content elements of the certification, the ninety-days-before and thirty-days-after face-to-face window with a nurse practitioner among the practitioner types who may perform it, that the encounter may occur by telehealth, the at-least-every-sixty-days recertification interval, and the financial-relationship bar at 42 CFR 411.354.3Ref 3Centers for Medicare & Medicaid Services (HHS) (2026).§ 484.2 Definitions..The definitional claims that allowed practitioner means a physician assistant, nurse practitioner or clinical nurse specialist, that nurse practitioner is defined by reference to 42 CFR 410.75(a) and (b) working in collaboration with a physician under 410.75(c)(3), and that physician in the home health conditions means an MD, DO or DPM.. The hospice rule does neither, and certification of terminal illness is reserved to physicians 4Ref 4Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.22 Certification of terminal illness..Who the written hospice certification of terminal illness must come from for the initial and subsequent benefit periods, including that the attending physician is named only if the patient has one, the six-months-or-less prognosis wording, the physician narrative requirement, and that a hospice physician or hospice nurse practitioner performs and attests to the face-to-face encounter before the third benefit period and each one after it., which CMS restates in its own manual 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount..

Each order then adds a second test: six required elements on a DME written order, a face-to-face encounter inside a defined window for home health, a physician narrative for hospice. A correctly signed order comes apart on one of those tests.

DME: the order is yours, with six elements on it

Yours to write and sign. Medicare's DMEPOS regulation defines the ordering role as treating practitioner and puts a nurse practitioner in that definition alongside a physician, a physician assistant and a clinical nurse specialist 1Ref 1Centers for Medicare & Medicaid Services (HHS) (2026).§ 410.38 Durable medical equipment, prosthetics, orthotics and supplies (DMEPOS): Scope and conditions..That the DMEPOS rule defines the ordering role as treating practitioner and includes a nurse practitioner in it, that every DMEPOS item needs a written order with six elements including the treating practitioner's name or NPI and signature, the split between orders due before delivery and orders due before claim submission, and the six-month face-to-face requirement for power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.. A walker, a hospital bed, a wheelchair: the order is your order. A supplier asking for a physician co-signature on NP notes is asking for something the DMEPOS rule does not require.

Every DMEPOS item needs a written order or prescription for Medicare to pay, and the regulation lists six elements it must carry, among them the treating practitioner's name or NPI and signature 1Ref 1Centers for Medicare & Medicaid Services (HHS) (2026).§ 410.38 Durable medical equipment, prosthetics, orthotics and supplies (DMEPOS): Scope and conditions..That the DMEPOS rule defines the ordering role as treating practitioner and includes a nurse practitioner in it, that every DMEPOS item needs a written order with six elements including the treating practitioner's name or NPI and signature, the split between orders due before delivery and orders due before claim submission, and the six-month face-to-face requirement for power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.. Write all six on the order itself rather than leaving the supplier to assemble them from the chart note.

But the timing is where these orders come apart. For most items the written order has to reach the supplier before the claim goes in. For power mobility devices and everything else on the Required Face-to-Face Encounter and Written Order Prior to Delivery List, the order has to reach the supplier before delivery. The treating practitioner must also have documented a face-to-face encounter within the six months preceding the order date 1Ref 1Centers for Medicare & Medicaid Services (HHS) (2026).§ 410.38 Durable medical equipment, prosthetics, orthotics and supplies (DMEPOS): Scope and conditions..That the DMEPOS rule defines the ordering role as treating practitioner and includes a nurse practitioner in it, that every DMEPOS item needs a written order with six elements including the treating practitioner's name or NPI and signature, the split between orders due before delivery and orders due before claim submission, and the six-month face-to-face requirement for power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List.. Check the list before you promise a patient a delivery date.

Home health: certify and recertify under your own signature

Also yours. Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, and the regulation puts the two on the same footing in one sentence rather than having one deputize for the other 2Ref 2Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.22 Requirements for home health services..That Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, the five content elements of the certification, the ninety-days-before and thirty-days-after face-to-face window with a nurse practitioner among the practitioner types who may perform it, that the encounter may occur by telehealth, the at-least-every-sixty-days recertification interval, and the financial-relationship bar at 42 CFR 411.354.. The home health conditions define allowed practitioner as a physician assistant, nurse practitioner or clinical nurse specialist 3Ref 3Centers for Medicare & Medicaid Services (HHS) (2026).§ 484.2 Definitions..The definitional claims that allowed practitioner means a physician assistant, nurse practitioner or clinical nurse specialist, that nurse practitioner is defined by reference to 42 CFR 410.75(a) and (b) working in collaboration with a physician under 410.75(c)(3), and that physician in the home health conditions means an MD, DO or DPM.. Physician in those same definitions means an MD, a DO or a DPM 3Ref 3Centers for Medicare & Medicaid Services (HHS) (2026).§ 484.2 Definitions..The definitional claims that allowed practitioner means a physician assistant, nurse practitioner or clinical nurse specialist, that nurse practitioner is defined by reference to 42 CFR 410.75(a) and (b) working in collaboration with a physician under 410.75(c)(3), and that physician in the home health conditions means an MD, DO or DPM..

The certification carries five content elements. It rests on a face-to-face encounter that must have occurred no more than 90 days before the home health start of care or within 30 days after it 2Ref 2Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.22 Requirements for home health services..That Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, the five content elements of the certification, the ninety-days-before and thirty-days-after face-to-face window with a nurse practitioner among the practitioner types who may perform it, that the encounter may occur by telehealth, the at-least-every-sixty-days recertification interval, and the financial-relationship bar at 42 CFR 411.354.. A nurse practitioner is among the practitioner types the regulation names as able to perform it, and the encounter may occur through telehealth subject to the statutory telehealth conditions 2Ref 2Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.22 Requirements for home health services..That Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, the five content elements of the certification, the ninety-days-before and thirty-days-after face-to-face window with a nurse practitioner among the practitioner types who may perform it, that the encounter may occur by telehealth, the at-least-every-sixty-days recertification interval, and the financial-relationship bar at 42 CFR 411.354..

One limit is structural. A physician or allowed practitioner with a financial relationship with the home health agency, as defined at 42 CFR 411.354, may not certify for it 2Ref 2Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.22 Requirements for home health services..That Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, the five content elements of the certification, the ninety-days-before and thirty-days-after face-to-face window with a nurse practitioner among the practitioner types who may perform it, that the encounter may occur by telehealth, the at-least-every-sixty-days recertification interval, and the financial-relationship bar at 42 CFR 411.354..

The allowed practitioner definition carries a condition worth reading before a first certification: it defines a nurse practitioner by reference to 42 CFR 410.75(a) and (b) and to working in collaboration with a physician under 410.75(c)(3) 3Ref 3Centers for Medicare & Medicaid Services (HHS) (2026).§ 484.2 Definitions..The definitional claims that allowed practitioner means a physician assistant, nurse practitioner or clinical nurse specialist, that nurse practitioner is defined by reference to 42 CFR 410.75(a) and (b) working in collaboration with a physician under 410.75(c)(3), and that physician in the home health conditions means an MD, DO or DPM.. What that collaboration looks like on paper is a state question, so confirm whether your state requires a collaborative agreement or protocol and what it has to contain.

Hospice: certifying terminal illness is a physician act

Not yours, and this is the one hard no of the three. The written certification of terminal illness must come from the hospice medical director, the physician designee, or the physician member of the hospice interdisciplinary group, plus any attending physician the patient has, for the initial 90-day period 4Ref 4Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.22 Certification of terminal illness..Who the written hospice certification of terminal illness must come from for the initial and subsequent benefit periods, including that the attending physician is named only if the patient has one, the six-months-or-less prognosis wording, the physician narrative requirement, and that a hospice physician or hospice nurse practitioner performs and attests to the face-to-face encounter before the third benefit period and each one after it.. CMS puts it flatly in Chapter 9 of the Benefit Policy Manual: nurse practitioners and physician assistants cannot certify or re-certify an individual as terminally ill 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount..

The certification states a prognosis of six months or less if the terminal illness runs its normal course, and the certifying physician writes a brief narrative explaining the clinical findings behind it 4Ref 4Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.22 Certification of terminal illness..Who the written hospice certification of terminal illness must come from for the initial and subsequent benefit periods, including that the attending physician is named only if the patient has one, the six-months-or-less prognosis wording, the physician narrative requirement, and that a hospice physician or hospice nurse practitioner performs and attests to the face-to-face encounter before the third benefit period and each one after it.. Hospice benefit periods run as two 90-day periods followed by an unlimited number of 60-day periods, each one needing its own certification 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount..

Where the patient's attending is a nurse practitioner or a physician assistant, the hospice medical director or the interdisciplinary group physician member signs the certification instead 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount.. An NP also may not serve as hospice medical director or as the physician member of the interdisciplinary group, so neither route reopens the signature 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount..

What an NP can still do on a hospice case

Be the attending, do the recertification visit, and bill for the care. Federal rules define hospice attending physician to include a nurse practitioner who meets the training, education and experience requirements at 42 CFR 410.75(b), identified by the patient at election as the practitioner with the most significant role in their medical care 6Ref 6Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.3 Definitions..The definitional claim that a hospice attending physician may be a nurse practitioner meeting the training, education and experience requirements at 42 CFR 410.75(b), identified by the patient at election as having the most significant role in their medical care.. The role is real, but it does not carry the certification signature.

The recertification visit is the clearest case. Before the third benefit period recertification and every one after it, a hospice physician or a hospice nurse practitioner must have a face-to-face encounter with the patient no more than 30 calendar days before the period begins, and whoever did it attests in writing to the visit and its date 4Ref 4Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.22 Certification of terminal illness..Who the written hospice certification of terminal illness must come from for the initial and subsequent benefit periods, including that the attending physician is named only if the patient has one, the six-months-or-less prognosis wording, the physician narrative requirement, and that a hospice physician or hospice nurse practitioner performs and attests to the face-to-face encounter before the third benefit period and each one after it.. An NP can be that practitioner. A physician still signs the certification the encounter supports.

Attending services are billable on conditions, and one of them repeats the certification bar: the services must be reasonable and necessary, the NP must be the patient's chosen attending, and they must not relate to certification of terminal illness 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount.. Medicare pays an NP 85% of the physician fee schedule amount for those visits 5Ref 5Centers for Medicare & Medicaid Services (2024).Medicare Benefit Policy Manual, Chapter 9 - Coverage of Hospice Services Under Hospital Insurance.CMS's own statement that nurse practitioners and physician assistants cannot certify or re-certify a terminal illness, that the hospice medical director or interdisciplinary group physician member certifies where the attending is an NP or PA, that an NP may not serve as medical director or as the physician member of the interdisciplinary group, the benefit period structure of two ninety-day periods followed by unlimited sixty-day periods, and the NP attending billing conditions including payment at 85 percent of the physician fee schedule amount..

All of this is the text in force on September 1, 2026, and the hospice certification section carries a cross-reference to an amendment published in the Federal Register on August 3, 2026. Read the current section before relying on a window in it 4Ref 4Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.22 Certification of terminal illness..Who the written hospice certification of terminal illness must come from for the initial and subsequent benefit periods, including that the attending physician is named only if the patient has one, the six-months-or-less prognosis wording, the physician narrative requirement, and that a hospice physician or hospice nurse practitioner performs and attests to the face-to-face encounter before the third benefit period and each one after it..

Why a correct order still comes back rejected

Because the second test is enrollment, not authority. A DMEPOS, imaging or laboratory claim must carry the ordering practitioner's legal name and NPI, and that practitioner must be enrolled in Medicare in an approved status or have validly opted out 7Ref 7Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.507 Ordering covered items and services for Medicare beneficiaries..The enrollment condition attached to the signature: that a DMEPOS, imaging or laboratory claim must carry the ordering practitioner's legal name and NPI and that the practitioner must be enrolled in Medicare in an approved status or validly opted out, and that the paragraph names the physician assistant, nurse practitioner or clinical nurse specialist for home health while naming only the ordering or certifying physician for hospice.. The supplier's claim is what fails, so the supplier is what refuses your order. Nothing in that refusal is a statement about what a nurse practitioner may sign.

It is the same shape as a pharmacy refusing an NP's prescription. The refusal comes from a system checking one field, and the fix is the field rather than an argument about scope of practice. An NP who bills nothing to Medicare directly can still satisfy the test through ordering-only PECOS enrollment. A valid opt-out satisfies it too: the regulation states the condition as an alternative 7Ref 7Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.507 Ordering covered items and services for Medicare beneficiaries..The enrollment condition attached to the signature: that a DMEPOS, imaging or laboratory claim must carry the ordering practitioner's legal name and NPI and that the practitioner must be enrolled in Medicare in an approved status or validly opted out, and that the paragraph names the physician assistant, nurse practitioner or clinical nurse specialist for home health while naming only the ordering or certifying physician for hospice..

That enrollment regulation mirrors the three-way split above: it names the physician assistant, nurse practitioner or clinical nurse specialist working in accordance with State law for home health, and only the ordering or certifying physician for hospice 7Ref 7Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.507 Ordering covered items and services for Medicare beneficiaries..The enrollment condition attached to the signature: that a DMEPOS, imaging or laboratory claim must carry the ordering practitioner's legal name and NPI and that the practitioner must be enrolled in Medicare in an approved status or validly opted out, and that the paragraph names the physician assistant, nurse practitioner or clinical nurse specialist for home health while naming only the ordering or certifying physician for hospice..

Every rule here is Medicare fee-for-service. Medicaid programs and Medicare Advantage plans run on their own published policies, and a plan refusing direct NP credentialing is a different problem with a different answer.

Before the signature leaves your desk

Three checks, one per order type, and all three take a few minutes at the desk. Confirm your Medicare enrollment status is approved or that your opt-out is on file, because that is what the supplier's or agency's claim gets tested against 7Ref 7Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.507 Ordering covered items and services for Medicare beneficiaries..The enrollment condition attached to the signature: that a DMEPOS, imaging or laboratory claim must carry the ordering practitioner's legal name and NPI and that the practitioner must be enrolled in Medicare in an approved status or validly opted out, and that the paragraph names the physician assistant, nurse practitioner or clinical nurse specialist for home health while naming only the ordering or certifying physician for hospice.. Confirm the face-to-face encounter exists, is documented, and sits inside the window the order needs. Confirm, on any hospice case, that a physician is signing the certification.

The three windows:

• DME on the face-to-face and written-order-prior-to-delivery list: an encounter within the six months preceding the order date, with the order to the supplier before delivery 1Ref 1Centers for Medicare & Medicaid Services (HHS) (2026).§ 410.38 Durable medical equipment, prosthetics, orthotics and supplies (DMEPOS): Scope and conditions..That the DMEPOS rule defines the ordering role as treating practitioner and includes a nurse practitioner in it, that every DMEPOS item needs a written order with six elements including the treating practitioner's name or NPI and signature, the split between orders due before delivery and orders due before claim submission, and the six-month face-to-face requirement for power mobility devices and other items on the Required Face-to-Face Encounter and Written Order Prior to Delivery List..
• Home health: an encounter no more than 90 days before the start of care or within 30 days after it, then recertification at least every 60 days 2Ref 2Centers for Medicare & Medicaid Services (HHS) (2026).§ 424.22 Requirements for home health services..That Medicare pays for home health only if a physician or an allowed practitioner certifies and recertifies eligibility, the five content elements of the certification, the ninety-days-before and thirty-days-after face-to-face window with a nurse practitioner among the practitioner types who may perform it, that the encounter may occur by telehealth, the at-least-every-sixty-days recertification interval, and the financial-relationship bar at 42 CFR 411.354..
• Hospice, third benefit period and after: an encounter no more than 30 calendar days before the period begins, attested in writing by the hospice physician or NP who performed it 4Ref 4Centers for Medicare & Medicaid Services (HHS) (2026).§ 418.22 Certification of terminal illness..Who the written hospice certification of terminal illness must come from for the initial and subsequent benefit periods, including that the attending physician is named only if the patient has one, the six-months-or-less prognosis wording, the physician narrative requirement, and that a hospice physician or hospice nurse practitioner performs and attests to the face-to-face encounter before the third benefit period and each one after it..

Write the date of the encounter on the order or the certification itself. It is the field a reviewer looks for first.