Hospice Face-to-Face (FTF) Encounters Frequently Asked Questions
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- What if the FTF is not completed prior to the start of the 3rd or later benefit period?
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If the FTF is not completed timely (prior to, but no more than 30 calendar days prior to the third benefit period recertification and every benefit period recertification thereafter), the patient would cease to be eligible for the Medicare hospice benefit (unless one of the exceptional circumstances was met – see FAQ #4 below) and the hospice must discharge the patient from the Medicare hospice benefit. In these cases, CMS expects the hospice to continue to care for the patient at the hospice's own expense until the required encounter occurs. The hospice can readmit the patient to the Medicare hospice benefit once the required FTF encounter occurs, provided the patient continues to meet all of the eligibility criteria and the patient (or representative) files an election statement as required by Medicare. For more information, refer to Change Request 7478
.Reviewed: 03.27.17
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- A hospice physician is required to conduct the FTF. What is the definition of a "hospice physician"?
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A hospice physician is a physician either employed by or under arrangement with a hospice (i.e. contracted). This is defined at 42 CFR 418.3
, which states: "Employee means a person who: (1) Works for the hospice and for whom the hospice is required to issue a W-2 form on his or her behalf; (2) if the hospice is a subdivision of an agency or organization, an employee of the agency or organization who is assigned to the hospice; or (3) is a volunteer under the jurisdiction of the hospice.Reviewed: 03.27.17
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- Can the physician/nurse practitioner (NP) bill for his/her services for conducting the FTF?
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The hospice FTF encounter is part of a hospice's administrative services and is not billable. However, if the physician or NP (who was identified by the patient as their attending physician) provides services that are medically reasonable and necessary while conducting the FTF, that portion of the visit can be billed by the hospice. See the Medicare Benefit Policy Manual (CMS. Pub. 100-02), Ch. 9, §40.1.3
for additional information. Reminder: The NP must be a W-2 employee of the hospice.Reviewed: 03.27.17
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- What constitutes an exceptional circumstance for the FTF encounter?
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An exceptional circumstance only applies to patients who are being admitted to hospice care and are entering their 3rd or later hospice benefit period. The Medicare Benefit Policy Manual (CMS Pub. 100-02), Ch. 9 § 20.1
gives examples of an emergency weekend admission, or when CMS data systems (e.g. ELGH and ELGA) are unavailable. In these documented cases, a face-to-face encounter which occurs within 2 days after admission will be considered to be timely. In addition, if a patient dies within 2 days of admission without a face-to-face encounter, a face-to-face encounter can be considered complete.Reviewed: 03.27.17
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- If a patient is admitted on Friday afternoon (in the patient's third or later benefit period), can the face-to-face encounter wait until Monday or must it be completed on Sunday?
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According to the CMS Medicare Benefit Policy Manual, Publication 100-09, Chapter 9, §20.1
, exceptional circumstances allow a face-to-face encounter within two days after admission. Sunday would be the 2nd day after admission. The face-to-face encounter could not wait until Monday following a Friday admission.Reviewed: 03.27.17
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- Can the FTF encounter be done on the same day/immediately prior to the patient's admission to hospice?
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Yes, the FTF can be completed on the day of admission and still be considered timely. For additional information, refer to the CMS Medicare Benefit Policy Manual, Ch. 9, §20.1.
Reviewed: 03.27.17
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- Can the patient's attending physician do the FTF if they are not employed, contracted, or a volunteer of the hospice?
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No, the regulation requires the FTF be done by a hospice physician or hospice nurse practitioner who is employed, contracted, or a volunteer of the hospice. (See FAQ #2 above). For additional information, refer to the CMS Medicare Benefit Policy Manual, Ch. 9, §20.1
Reviewed: 03.27.17
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- What documentation is required for the FTF encounter if the claim is selected for Medical Review?
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The hospice physician/NP who completes the FTF must attest in writing that he/she completed the FTF encounter with the patient, and include their signature and the date of the encounter. When the hospice NP performs the FTF, the attestation must also state that the clinical findings were provided to the certifying physician to determine the terminal status of the patient. The clinical findings of the face-to-face encounter are used in the narrative associated with the third benefit period recertification and every subsequent recertification to provide an explanation of why the clinical findings of the face-to-face encounter support a life expectancy of 6 months or less. For additional information, refer to the CMS Medicare Benefit Policy Manual, Ch. 9, §20.1
Reviewed: 03.27.17
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- How can a hospice verify whether a patient is being admitting to a 3rd or later benefit period?
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Hospice providers can utilize ELGA or ELGH, or the HIPAA Eligibility Transaction System (HETS) to determine which benefit period the beneficiary is entering. For more information on ELGA/ELGH, refer to Chapter 2: Checking Beneficiary Eligibility
of the FISS Guide.Reviewed: 03.27.17
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- Is the hospice physician who does the FTF required to be the same physician who signs the recertification?
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The hospice physician who completed the FTF is not required to be the same physician who signs the recertification.
Reviewed: 03.27.17
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