Unusual Circumstances: Face to Face Encounters

Prior to the third hospice benefit period, and prior to each subsequent benefit period, a hospice physician or nurse practitioner is required to have a face to face encounter with the hospice patient to recertify that the patient continues to be Medicare eligible for hospice benefits.  The face to face encounter must occur within 30 calendar days prior to the start of the third benefit period and each subsequent benefit period.

The face to face encounter is necessary to recertify that the patient remains eligible for Medicare hospice benefits. If face to face encounters are not performed timely, the patient is is no longer hospice eligible. The hospice may continue to provide hospice services to the patient but may no longer continue to bill Medicare. Instead, the hospice would need to assume all financial responsibility for the patient until such time that the hospice is able to reestablish patient hospice eligibility. The patient may be readmitted to hospice once hospice eligibility criteria are once again met.

What if there are exceptional circumstances that cause the hospice to be unable to timely complete the face to face encounter?

What are exceptional circumstances?

If a patient is admitted and is in the third benefit period or later, the hospice agency may be unable to perform the face to face encounter prior to the start of the benefit period.

For example, if the patient is an emergency weekend admission and the nurse practitioner or hospice physician is unable to meet with the patient prior to hospice admission. The patient is only seen the following Monday.

Another exceptional circumstance may be where the CMS data system is unavailable and the hospice agency is unaware that the patient is in the third or later benefit period.

In these documented exceptional circumstances, the face to face encounter is considered timely if it is completed within two days after admission.

In addition, if the patient dies within two days of admission, the face to face encounter is considered complete.

Where can you get more information?

Details on Medicare Face to Face encounter requirements: Medicare F2F encounter requirements