Hospice FAQs

Q. What is the timeframe of the hospice face-to-face encounter?

A. The encounter must occur no more than 30 calendar days prior to the start of the third benefit period and no more than 30 calendar days prior to every subsequent benefit period thereafter.

Q. What happens if the face-to-face encounter does not occur within the required timeframes for hospice?

A. The following are exceptional circumstances to the face-to-face encounter timeframe for new hospice admissions in the third or later benefit period:

In cases where a hospice newly admits a patient who is in the third or later benefit period, exceptional circumstances may prevent a face-to-face encounter prior to the start of the benefit period. For example, if the patient is an emergency weekend admission, it may be impossible for a hospice physician or nurse practitioner (NP) to see the patient until the following Monday. Or, if the Centers for Medicare & Medicaid Services (CMS) eligibility data systems are unavailable, the hospice may be unaware that the patient is in the third benefit period. In such documented cases, a face-to-face encounter which occurs within two days after admission will be considered to be timely. Additionally, for such documented exceptional cases, if the patient dies within two days of admission without a face-to-face encounter, a face-to-face encounter can be deemed as complete.

Q. What are the attestation requirements?

A. A hospice physician or nurse practitioner (NP) who performs the face-to-face encounter must attest in writing that he or she had a face-to-face encounter with the patient, including the date of the encounter. The attestation, its accompanying signature, and the date signed, must be a separate and distinct section of, or an addendum to, the recertification form, and must be clearly titled. Where a NP performed the encounter, the attestation must state that the clinical findings of that visit were provided to the certifying physician, for use in determining whether the patient continues to have a life expectancy of six months or less, should the illness run its’ normal course.

Q. Who can perform the hospice face-to-face encounter?

A. A hospice physician or a hospice nurse practitioner (NP) can perform the encounter. A hospice physician is a physician who is employed by the hospice or working under contract with the hospice. A hospice NP must be employed by the hospice. A hospice employee is one who receives a W-2 from the hospice or who volunteers for the hospice.

Q. Can the hospice bill using the occurrence span code 77 to reflect non-covered days when the face-to-face encounter occurs late, after the required timeframe?

A. No. The law requires that the face-to-face encounter must occur prior to the start of the benefit period in order for eligibility to continue.

When a discharge from the Medicare hospice benefit occurs due to failure to perform a required face-to-face encounter timely, the claim should include the most appropriate patient discharge status code. The hospice can re-admit the patient to the Medicare hospice benefit once the required face-to-face encounter occurs, provided the patient continues to meet all of the eligibility requirements and the patient (or representative) files an election statement in accordance with the Centers for Medicare & Medicaid Services (CMS) regulations.

Q. What happens if the face-to-face encounter for hospice occurs timely, but the attestation is completed later?

A. While the face-to-face encounter itself must occur no more than 30 calendar days prior to the start of the third benefit period recertification and each subsequent recertification, its’ accompanying attestation must be completed prior to the submission of the claim.

Q. Can a hospice face-to-face encounter occur on the same day that the new hospice period begins?

A. Yes. The hospice face-to-face encounter must occur prior to, but no more than 30 calendar days prior to, the third benefit period recertification and every benefit period recertification thereafter. The face-to face encounter is one part of a hospice recertification, so a recertification is not complete until it occurs. Therefore, by definition, a face-to-face encounter always occurs prior to recertification. We also require that each benefit period (after the first one) be recertified, and recertifications are to occur no more than 15 days prior to the start of the benefit period. This timeframe does not preclude the hospice face-to-face encounter from occurring on the same day that the new benefit period begins. We allow hospice providers the flexibility to complete the face-to-face encounter during the first day of the new benefit period. (CMS FAQ 6099)

Q. Is the face-to-face encounter visit billable?

A. If a physician provides a medically reasonable and necessary physician service to the patient during the visit, that portion of the visit may be billable.

Q. What are the signature requirements for the face-to-face encounter?

A. The recertifying physician’s attestation regarding the face-to-face encounter can be included on the recertification itself or as an addendum to the recertification. If the attestation is included on the recertification, it must be located above the physician’s signature. One physician signature may suffice for the attestation, narrative and recertification.

Where both the encounter attestation and narrative are included as an addendum to the recertification, one physician signature can suffice for both the narrative and attestation. Both the narrative and the attestation must be located above the physician signature.

The practitioner who performed the encounter must sign the attestation. If a practitioner other than the recertifying physician (such as an nurse practitioner (NP)) performed the encounter, a separate encounter attestation signature is required. The encounter attestation can be on the same page as the recertification and narrative, but must be a separate section above the signature of the practitioner who performed the encounter. The attestation can also be a signed addendum to the certification.
Only the recertifying physician can sign the certification and physician narrative.

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