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Hospice Face-to-Face (FTF) Encounter

The recertification associated with a hospice patient's third benefit period, and every subsequent recertification, must include documentation that a hospice physician or a hospice nurse practitioner had a face-to-face (FTF) encounter with the patient. The FTF encounter must document the clinical findings supporting a life expectancy of 6 months or less. When the FTF requirements are not met, the patient is no longer eligible for the Medicare hospice benefit.

Time Frame for the Encounter

The FTF encounter must occur within 30 calendar days prior to the start of the 3rd benefit period and each subsequent recertification. In documented exceptional circumstances, for a new hospice admission in the third or later benefit period, the FTF encounter is considered to be timely when performed within 2 days after admission. Examples include:

  • An emergency weekend admission and the patient cannot be seen by the hospice physician or the nurse practitioner (NP) until the following Monday.
  • Unavailable CMS data systems resulting in the inability for the hospice to determine if the patient is in the 3rd benefit period.

In addition, if the patient dies within 2 days of admission, a FTF encounter is considered to be complete.

Untimely Face-to-Face Encounter

When a required face-to-face (FTF) encounter does not occur timely, the beneficiary is no longer certified as terminally ill, and therefore, is not eligible for the Medicare hospice benefit. In these cases, the hospice must discharge the beneficiary from the Medicare hospice benefit because he/she is no longer considered terminally ill for Medicare purposes. When a discharge occurs due to failure to perform a required FTF encounter timely, the claim should include appropriate billing information. For additional information about how to bill correctly, refer to the CGS "Untimely Face-To-Face Encounter" Web page.

Who Performs and Signs the FTF Encounter

The FTF encounter must be performed by a hospice physician or a hospice NP. The hospice physician must be employed by the hospice, a volunteer, or working under contract. The hospice NP must be employed by the hospice (receives a W-2 form from the hospice or volunteers for the hospice).

FTF Requirements

The hospice physician or NP must attest in writing that he or she had a FTF encounter with the patient, including the date of the encounter. The attestation, which must be a separate and distinct part of the recertification, or as an addendum to the recertification associated with the 3rd benefit period, must meet the following criteria:

  • Clearly titled.
  • Accompanying signature, and date signed by the individual who performed the visit.
  • Date of the visit.
  • Clinical findings to determine continued hospice eligibility.
  • When the hospice NP/non-certifying physician performs the FTF, the attestation must also state that the clinical findings were provided to the certifying physician.

Billing Responsibilities

Before submitting claims to CGS, hospice agencies should ensure:

  • All FTF requirements are met; and
  • The written certification, including the narrative and FTF, is signed prior to billing the claim.

Additional Resources

Reviewed: 12.20.21


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