Face-to-Face Encounter
Hospice
As a condition for reimbursement of hospice services, the Centers for Medicare and Medicaid Services has implemented a new rule requiring patient/physician face-to-face encounters for hospice patients who are expected to reach the third benefit period (usually on the 180th day).
Who qualifies to perform the face-to-face encounter?
- A hospice physician, defined as a physician either employed by or working under arrangement with a hospice
- Residents and fellows who are employed or under agreement with the hospice agency
- Employed nurse practitioners
When does the face-to-face encounter need to take place?
- Up to 30 days prior to the beginning of the third or later benefit period (usually begins on the 180th day)
- The total recertification process (face-to-face encounter, physician narrative and signed certification of terminal illness) must be complete 15 days prior to the beginning of the third or greater benefit period (usually begins on 180th day)
What should be included in the documentation of the face-to-face encounter?
- Date of the visit
- Hospice physician attestation
- Hospice physician/medical director/nurse practitioner signature and date