Face-to-Face (FTF) Encounter Requirements in Hospice Care

Overview

For patients entering their third or later hospice benefit period, a face-to-face (FTF) visit is a federal requirement that helps validate continued eligibility for hospice care. This rule—effective for benefit periods starting on or after January 1, 2011—ensures that patients continue to meet the criteria for terminal illness under Medicare’s guidelines.

This guide will break down who must perform the FTF, when and where it should be conducted, what documentation is needed, and billing considerations for hospice providers.

Who Can Perform the Face-to-Face Encounter?

The FTF must be conducted by one of the following:

• A physician employed, contracted, or volunteering with the hospice agency.

• A nurse practitioner (NP) who is employed by the hospice (whether full-time, part-time, or per diem).

Important Limitation: Although NPs can perform the FTF, they are not allowed to sign the recertification of terminal illness. Only a hospice physician can do that.

When Must the Face-to-Face Encounter Occur?

The FTF must take place:

• Within the 30 calendar days leading up to the start of the third benefit period, and before every subsequent recertification.

If the hospice cannot reasonably conduct the FTF in advance due to documented exceptional circumstances, the visit is considered timely if performed within two days after admission. Acceptable exceptions may include:

• Emergency weekend admissions when providers are unavailable until Monday.

• System outages (e.g., CMS data platforms) that prevent timely benefit period verification.

• The patient passes away within two days of admission during a third or later benefit period.

Where Should the FTF Take Place?

The encounter may happen:

• In the patient’s place of residence, such as their home or long-term care facility.

• In a clinical setting, such as a physician's or NP’s office, if the patient is able to travel safely.

Telehealth is not permitted for hospice FTF encounters. These visits must be conducted in person to meet Medicare requirements.

What Must Be Documented?

Thorough documentation is essential for regulatory compliance and reimbursement. The following must be included:

• Clinical observations from the FTF visit that support the patient’s ongoing eligibility for hospice (i.e., a life expectancy of six months or less).

• A written attestation by the clinician who performed the FTF, confirming the encounter took place and including:

  • The date of the FTF visit.

  • A statement that the encounter was completed in person.

  • If the encounter was done by an NP, a declaration that their clinical findings were shared with the certifying hospice physician.

• The FTF attestation must be:

  • Signed and dated by the provider who performed the visit.

  • A distinct section of the certification form, or a clearly labeled addendum.

Without proper FTF documentation, the hospice cannot legally submit claims for the associated benefit period.

Transferring Hospice Patients and the FTF Requirement

If a patient who is in their third or later benefit period transfers to a new hospice provider, the new agency does not need to repeat the FTF visit—as long as documentation from the prior hospice confirms that the FTF was completed and meets all requirements.

Billing & Reimbursement Notes

• The FTF visit itself is an administrative component of the recertification process and is not separately billable.

• If the provider delivers additional medically necessary care during the encounter (e.g., pain or symptom management), these professional services can be included on the hospice claim.

• NPs may only bill for professional services if they are designated by the patient as the attending provider (which is separate from the FTF role).

Certification Timing Reminders

• The entire certification process—including the FTF visit, physician narrative, and all required signatures—can be completed up to 15 days before the benefit period starts.

• Certifications and recertifications must clearly show the dates of the benefit period they cover.

• All components of the certification—including the FTF and physician attestation—must be completed and signed before the claim is submitted to Medicare.

Ensuring Compliance

Failing to complete the FTF properly can jeopardize reimbursement and trigger survey deficiencies. Hospice agencies should develop internal protocols to track benefit periods, schedule FTF visits timely, and audit documentation for accuracy and completeness.

At SummitRidge, we offer compliance audits, documentation templates, and training tools to ensure your hospice team meets all CMS and Medicare FTF requirements—on time and with confidence.