Notify patients of face-to-face visits

Alleviate concerns with info, familiar face

The most important steps for a hospice manager to take to be sure hospice patients entering their third and subsequent benefit periods is to expand or initiate new contracts with physicians to provide coverage for the face-to-face encounters, says Sandy Kuhlman, executive director of Hospice Services in Phillipsburg, KS.

After you've made sure you have physician coverage, there are a number of other steps a hospice manager should take to ensure compliance and to prepare patients for the visits, points out Kuhlman.

"We developed a notification process that includes a letter hand-delivered by the patient's nurse to the patient and family that explains the physician's upcoming visit," says Kuhlman.

Information about cuts in services during the healthcare reform debate might cause some patients and families to view the visit as an effort to end services, she points out. "These families are already in crisis, so we need to reassure them that the physician visit is part of our effort to provide excellent care and to evaluate the care we're providing," Kuhlman says.

At her hospice, the physician or nurse practitioner will be accompanied by a staff member who regularly cares for the patient so there is a familiar face for the patient and family, Kuhlman adds.

The trickiest part of meeting the requirements will be setting the schedule so no one is missed, says Judi Lund Person, MPH, vice president of compliance and regulatory leadership at the National Hospice and Palliative Care Organization. Patients who have been with one hospice since their start of care should not pose great problems to track, but in areas with multiple hospices and patients who move from hospice to hospice, there is the additional challenge of determining how many days the patient has already received hospice care, Lund Person says. "The face-to-face encounter must occur prior to the start of the third or subsequent 60-day benefit period, regardless of which hospice provided the care," she says. This requirement means a patient who received hospice care for the first 90-day benefit period from one hospice, then switched to a second hospice for the second 90-day benefit period, must be recertified with a face-to-face encounter prior to the start of the next benefit period, Lund Person says.

"You cannot count 180 days from the start of care within your hospice; it is 180 days from the start of care for any hospice," she explains. "Hospices will have to be diligent when they admit new patients. Although the Medicare Common Working File (CWF) contains all of the beneficiaries' information about past care, the nine databases that contain information do not "talk" to each other, points out Lund Person. "This means that up to nine different databases may need to be checked to ensure that the patient has not received hospice care somewhere else prior to admission to your hospice," she says. "This could extend the admission process for some hospices that experience a high number of admissions at one time without the staff to handle researching prior admissions."

Kuhlman says, "We would typically conduct database searches about four days a week, but to do a thorough search and quickly identify whether or not a patient has received previous hospice care, we will probably conduct the searches every day."

More importantly, an additional staff person has been trained to conduct the searches of the CWF to make sure no time is lost if the primary staff person is on vacation or out sick, she adds.

Once a patient is admitted and the clock starts ticking toward the recertification period, be sure you have a system to alert you to the need to schedule a face-to-face encounter, suggests Kuhlman. "We use an electronic records system that will generate a report showing when recertifications are due," she says. "One staff person is designated as the monitor of these reports to start the process early."

Although the face-to-face encounter cannot occur more than 30 days prior to the start of the next benefit period, the patient's record can be flagged and a visit can be scheduled for the correct timeframe, she says.

Executive Summary

As of Jan. 1, 2011, a physician who has conducted a face-to-face visit with the patient must certify hospice patients entering their third or subsequent benefit period eligible for hospice care. The new requirement focuses on recertification as a process with several components that include the face-to-face encounter, physician narrative, and attestations to the validity of documentation.

• Rural hospices or hospices with large numbers of long stay patients will face challenges in finding physicians to cover the visits.

• Nurse practitioners employed by the hospice can conduct the face-to-face visit and attest to providing the certifying physician with the information required for recertification.

• The face-to-face encounter can occur no more than 30 days prior to the beginning of the third or subsequent benefit period, and the certification must be dated no earlier than 15 days prior to the beginning of the benefit period.


For more information about complying with the face-to-face encounter requirement, contact:

• Sandy Kuhlman, Executive Director, Hospice Services, 424 Eighth St., Phillipsburg, KS 67661. Telephone: (800) 315-5122 or (785) 543-2900. Fax: (785) 543-5688. E-mail:

• Judi Lund Person, MPH, Vice President, Compliance and Regulatory Leadership, National Hospice and Palliative Care Organization, 1731 King St., Suite 100, Alexandria, VA 22314. Telephone: (703) 837-1500. Fax: (703) 837-1233. E-mail: