Requirements for face-to-face encounter

All components needed for compliance

Effective compliance with the requirements of the face-to-face encounter now in place for certifications of patients receiving the hospice benefit requires attention to proper documentation of the visit.

"Although the physician or nurse practitioner may conduct a physical assessment at the time of the encounter, it is not required," points out Judi Lund Person, MPH, vice president of compliance and regulatory leadership at the National Hospice and Palliative Care Organization. In addition to the face-to-face encounter required for recertification after 180 days of care, there are also specific requirements for certification of patients in their first and second benefit periods of care, Lund Person says. In all instances, a physician must perform the actual certification, even if the encounter is performed by a nurse practitioner who provides information to the physician, she adds.

Medicare Hospice Certification is now to be considered a process consisting of several distinct components, Lund Person points out. The following components may be combined on one page or across several pages as addendums to the actual certification page, but they must be independently present and clearly labeled.

The components for Medicare hospice patients in their first or second benefit period include:

• If a new hospice admission: A signed and dated certification by the attending physician, if there is an attending separate from the hospice physician.

• A physician narrative that provides a brief narrative explanation of the clinical findings that support a life expectancy of six months or less. This section must be composed by the physician and should reflect the patient's individual clinical circumstances and cannot contain check boxes or standard language used for all patients.

• Signed and dated narrative attestation that states, "By signing by signature, I attest that I composed the above narrative based on my review of the medical record or, if applicable, my examination of the patient." This attestation should appear above the signature.

• Hospice physician's signature and date for the certification.

For Medicare hospice patients entering their third or subsequent benefit periods, the previous requirements are needed along with:

• If a new admission to the current hospice: A signed and dated certification by the attending physician, if there is an attending separate from the hospice physician.

• Face-to-face encounter documentation.

• Signed and dated face-to-face encounter attestation that states that the hospice physician or nurse practitioner performed the face-to-face encounter. The attestation should include the date of the encounter. The attestation does not have to be dated the same date as the encounter.

If the face-to-face encounter was performed by a nurse practitioner, he or she must also attest that the information collected during the encounter was provided to the certifying physician.

• Physician narrative similar to narrative required for first two benefit period certifications.

• Signed and dated narrative attestation such as attestation required for first two benefit period certifications.

• Hospice physician's signature and date for the certification.

Other certification documentation considerations:

• The signing physician should date his or her own signature. If this is forgotten, evidence that the certification occurred on the specific date may be obtained using a notarized statement or other documentation acceptable to CMS or the Medicare administrative contractor.

• Dictated and transcribed encounter notes and narratives are permissible, though evidence may be requested to ensure that the physician composed the narrative himself or herself.

• Electronic or digital signatures and dates are permissible, as long as these comply with other CMS requirements for such signatures.1


1. American Academy of Hospice and Palliative Medicine. AAHPM Guide to Face-to-Face Encounters. Glenview, IL; 2010. Web: