08/22/2018
You Asked....We Answered
This week's You Asked..We Answered question asks: "Would it be out of compliance if the RN makes the recertification visit prior to F2F, the MD signs the cert with a narrative prior to the F2F but all is completed by the end of the certification period?"
You Asked:
Would it be out of compliance if the RN makes the recertification visit prior to F2F, the MD signs the cert with a narrative prior to the F2F but all is completed by the end of the certification period?
We Answered:
The reason for the F2F encounter is to determine if the patient is appropriate to remain on the hospice benefit, so the certification should not be signed (or the patient recertified) before the F2F is completed, even if the doctor is 99.9% certain the patient is still appropriate for hospice. The Medicare Benefit Manual Chapter 9 says:
20.1 - Timing and Content of Certification
- face-to-face encounter. For recertifications on or after January 1, 2011, a hospice physician or hospice nurse practitioner must have a face-to-face encounter with each hospice patient prior to the beginning of the patient’s third benefit period, and prior to each subsequent benefit period. Failure to meet the face-to-face encounter requirements specified in this section results in a failure by the hospice to meet the patient’s recertification of terminal illness eligibility requirement. The patient would cease to be eligible for the benefit.
The face to face encounter requirement is satisfied when the following criteria are met:
a. Timeframe of the encounter: The encounter must occur prior to the recertification for the third benefit period and each subsequent benefit period. The encounter must occur no more than 30 calendar days before the third benefit period recertification and each subsequent recertification. A face-to-face encounter may occur on the first day of the benefit period and still be considered timely. (Refer to section 20.1.5.d below for an exception to this timeframe).
b. Attestation requirements: A hospice physician or nurse practitioner 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, must be a separate and distinct section of, or an addendum to, the recertification form, and must be clearly titled. Where a nurse practitioner or non-certifying hospice physician performed the encounter, 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.
If you have a question you would like to see featured in You Asked..We Answered, email Nisha Hammel, Director of Advocacy at nhammel@leadingageohio.org , or Anne Shelley, Director of Professional Development & HH/Hospice Regulatory Relations, at ashelley@leadingageohio.org.
