Hospice Face-to-Face

A hospice physician or a hospice nurse practitioner (NP) can perform the encounter. A hospice physician is a physician who is employed by the hospice or working under contract with the hospice. A hospice NP must be employed by the hospice. A hospice employee is one who receives a W-2 from the hospice or who volunteers for the hospice.

Last Reviewed: 08/07/2026

The encounter must occur no more than 30 calendar days prior to the start of the third benefit period and no more than 30 calendar days prior to every subsequent benefit period thereafter. A face-to-face encounter may occur on the first day of the benefit period and still be considered timely.

Last Reviewed: 08/07/2026

In cases where a hospice newly admits a patient who is in the third or later benefit period, exceptional circumstances may prevent a face-to-face encounter prior to the start of the benefit period. For example, if the patient is an emergency weekend admission (Saturday or Sunday), it may be impossible for a hospice physician or NP to see the patient until the following Monday. Or, if CMS's eligibility data systems are unavailable, the hospice may be unaware that the patient is in the third benefit period.

In such documented cases, a face-to-face encounter which occurs within two days after admission will be considered to be timely. Additionally, for such documented exceptional cases, if the patient dies within two days of admission without a face-to-face encounter, a face-to-face encounter can be deemed as complete.

Last Reviewed: 08/07/2026

If the required face-to-face encounter is not timely, the hospice would be unable to recertify the patient as being terminally ill, and the patient would cease to be eligible for the Medicare hospice benefit. In such instances, the hospice must discharge the patient from the Medicare hospice benefit because he or she is not considered terminally ill for Medicare purposes.

The hospice can re-admit the patient to the Medicare hospice benefit once the required encounter occurs, provided the patient continues to meet all of the eligibility requirements and the patient (or representative) files an election statement in accordance with CMS regulations. Where the only reason the patient ceases to be eligible for the Medicare hospice benefit is the hospice’s failure to meet the face-to-face requirement, CMS would expect the hospice to continue to care for the patient at its own expense until the required encounter occurs, enabling the hospice to re-establish Medicare eligibility.

Last Reviewed: 08/07/2026

No. Occurrence span code 77 does not apply when the face-to-face encounter has not occurred timely. The hospice must discharge the patient from the Medicare hospice benefit if the face-to-face encounter does not occur within the required timeframes. See the "What is the timeframe of the hospice face-to-face encounter?" FAQ above for more detail.

Physician assistants, clinical nurse specialists and outside attending physicians are not authorized to perform the face-to-face encounter for recertification.

Last Reviewed: 08/07/2026

The recertifying physician’s attestation regarding the face-to-face encounter can be included on the recertification itself or as an addendum to the recertification. If the attestation is included on the recertification, it must be located above the physician’s signature. One physician signature may suffice for the attestation, narrative and recertification.

Where both the encounter attestation and narrative are included as an addendum to the recertification, one physician signature can suffice for both the narrative and attestation. Both the narrative and the attestation must be located above the physician signature.

The practitioner who performed the encounter must sign the attestation. If a practitioner other than the recertifying physician (such as an NP) performed the encounter, a separate encounter attestation signature is required. The encounter attestation can be on the same page as the recertification and narrative but must be a separate section above the signature of the practitioner who performed the encounter. The attestation can also be a signed addendum to the certification. Only the recertifying physician can sign the certification and physician narrative.

Last Reviewed: 08/07/2026

A hospice physician or NP who performs the encounter must attest in writing that he or she had a face-to-face encounter with the patient, including the date of the encounter. The attestation, its accompanying signature, and the date signed, may be a separate and distinct section of, or an addendum to, the recertification form, and must be clearly titled. The attestation requirement may also be fulfilled by not only a clearly titled section of or an addendum to the recertification form, but also by a signed and dated clinical note within the medical record that documents clear indication that the face-to-face encounter occurred and includes the date of the visit, the signature of the practitioner who conducted the face-to-face encounter, and the date of the signature.

Where a NP or non-certifying hospice physician performed the encounter, and the attestation is a separate and distinct section of, or an addendum to, the recertification, the attestation must state that the clinical findings of that visit were provided to the certifying physician, for use in determining whether the patient continues to have a life expectancy of 6 months or less, should the illness run its normal course.

Last Reviewed: 08/07/2026

While the face-to-face encounter itself must occur no more than 30 calendar days prior to the start of the third benefit period recertification and each subsequent recertification, its accompanying attestation must be completed prior to the submission of the claim.