After considerable comments, the Centers for Medicare & Medicaid Services (CMS) has decided not to finalize the requirement that the Social Worker, Marriage and Family Therapist (MFT), or Mental Health Counselor (MCH) be a member of the IDG “based on the needs and preferences of the patient.” This will allow hospices to maintain flexibility in identifying their Interdisciplinary Groups.
While CMS is modifying the proposed requirement, they stress that hospices have always had the option to have non-IDG staff that provide care for the patient to attend the IDG meetings to share patient status, issues/concerns, and recommendations. The hospice is not required to include all three of these professions as members of the IDG. The MFT or MHC must be hired as a direct employee which would include the options of hiring full time, part time or per diem.
Additionally, the 2008 hospice final rule and section 946 of the Medicare Modernization Act, a hospice (the primary hospice) may enter into arrangements with another Medicare-certified hospice to obtain core hospice services such as MFT or MCH.