What Is a Hospice Face-to-Face Encounter?

A hospice face-to-face encounter is a required visit by a hospice physician or hospice nurse practitioner to gather clinical findings that support continued hospice eligibility. It must happen no more than 30 calendar days before the 3rd benefit period recertification, and before every benefit period recertification after that (42 CFR 418.22(a)(4)). Through December 31, 2027, it can usually be done by real-time audio-video telehealth. It is a routine recertification step, not a test the patient can “fail” by living longer.

Question	Short answer
When is it required?	Before the 3rd benefit period and before each 60-day period after that
How early can it be done?	No more than 30 calendar days before the recertification; the first day of the new period still counts as timely
Who can do it?	A hospice physician (employed or contracted) or a hospice nurse practitioner employed by the hospice
Who cannot?	Physician assistants, clinical nurse specialists, and the patient’s outside attending physician
Can it be telehealth?	Yes, through December 31, 2027, by two-way real-time audio and video, with some exclusions
What if it is missed?	The recertification is incomplete; the hospice must discharge from the Medicare benefit but can keep caring at its own expense

When the face-to-face encounter happens

The Medicare hospice benefit runs in benefit periods: two 90-day periods, then an unlimited number of 60-day periods. The requirement starts with the third period, which begins after the first 180 days, and applies to any patient whose total stay across all hospices is expected to reach that period. In practice the visit falls in the last 30 days of the second 90-day period (or on the first day of the third), and then in the 30 days before each later 60-day period — so a long-staying patient has one roughly every two months.

Can the face-to-face encounter be done by telehealth?

Yes, for now. Under the current regulation, through December 31, 2027 (or during a declared public health emergency, if later), an encounter done solely for recertification may use telecommunications technology — meaning, at a minimum, two-way, real-time audio and video between the patient and the hospice physician or nurse practitioner. Audio-only calls do not meet that definition. Since January 31, 2026, telehealth cannot be used if:

• the patient is in an area under a Medicare hospice enrollment moratorium;
• the patient’s hospice is under enhanced oversight by CMS; or
• the physician or nurse practitioner is not enrolled in Medicare (and is not an opt-out practitioner).

CMS says the nationwide hospice moratorium will not impact the telehealth flexibility for these visits, so hospices that are already enrolled can continue to use telehealth for recertification encounters.

For encounters on or after January 1, 2027, hospices must report on the claim any face-to-face encounter done by telehealth, under the FY 2027 hospice payment rule.

Who can perform it

Only a hospice physician (employed by or under contract with the hospice) or a hospice nurse practitioner employed by the hospice. CMS states that physician assistants, clinical nurse specialists, and outside attending physicians are not authorized to perform it. A nurse practitioner can do the encounter but cannot recertify the terminal illness — a hospice physician still signs the recertification.

What happens at the visit

The physician or nurse practitioner sees the patient — at home, in the nursing facility, or wherever the patient lives, or by video when allowed — reviews the current condition, and documents clinical findings. The question is whether the patient still has a life expectancy of six months or less if the illness runs its normal course. It is usually a conversation and an examination, and having the caregiver present helps.

What has to be documented

The clinician who did the encounter must attest in writing that it happened, with the date of the visit, their signature, and the date signed. The attestation can be a clearly titled section of or addendum to the recertification, or a signed and dated clinical note that shows the encounter occurred and includes its clinical findings. If a nurse practitioner or a non-certifying hospice physician did the visit and the attestation is part of the recertification, it must state that the findings were given to the certifying physician. The certifying physician’s narrative for the 3rd and later recertifications must explain why the encounter’s findings support a prognosis of six months or less.

What happens if the encounter is missed or late

A recertification that needs a face-to-face encounter but lacks one is incomplete, and Medicare cannot pay without a complete recertification. According to the CMS Medicare Benefit Policy Manual, when the missed encounter is the only problem, the hospice is expected to discharge the patient from the Medicare hospice benefit but continue caring for the patient at its own expense until the encounter occurs. The hospice can then re-admit the patient to the benefit, as long as the patient still meets eligibility and the patient or representative signs a new election statement. The deadline is the hospice’s responsibility, not the family’s. If you are told care will stop because of a missed encounter, ask for the explanation in writing.

Exceptions: new admissions and transfers

• Patients newly admitted in the 3rd or a later period: if documented exceptional circumstances (such as an emergency weekend admission) prevent a visit before the period starts, an encounter within 2 days after admission is considered timely. If the patient dies within 2 days of admission without an encounter in such a case, it can be deemed complete.
• Transfers between hospices: the benefit period does not change, so a new encounter is not required if the receiving hospice can verify the previous hospice already did it. See how to switch hospice providers.

How it differs from a regular nurse visit

Feature	Routine nurse visit	Face-to-face encounter
Main purpose	Symptom and comfort care	Clinical findings for recertification
Who performs it	Usually a registered nurse	Hospice physician or hospice nurse practitioner
When	On the care schedule	Within 30 days before the 3rd period and each one after
Result	Updated plan of care	Signed attestation supporting recertification

The encounter itself is an administrative requirement and is not separately billable; CMS says any reasonable and necessary patient care given during the same visit can be billed under its rules.

It does not mean your loved one is being discharged

Families sometimes hear about the encounter and assume the patient is about to be removed from hospice. Its purpose is to document ongoing eligibility so care can continue. Living past six months does not by itself end hospice — see does hospice kick you out after 6 months and what happens if you live longer than 6 months on hospice. For the full renewal process, see how hospice recertification works.

How to help the visit go smoothly

Describe concrete changes since the last period: weight loss, eating or drinking less, more sleeping, new infections, falls, less ability to walk or transfer, or more frequent symptom flares. A running note between visits helps. Have the medication list handy and mention any hospital or ER visits. The clinical burden is on the hospice; accurate details simply help the team document what is really happening.

Frequently asked questions

When is the hospice face-to-face encounter due?

No more than 30 calendar days before the start of the 3rd benefit period, and before every 60-day period after that. An encounter on the first day of the new period is still timely.

Can a nurse practitioner do the face-to-face encounter?

Yes, if the nurse practitioner is employed by the hospice. A nurse practitioner cannot recertify the terminal illness, so a hospice physician still signs the recertification.

Can our regular doctor do it?

No. The patient’s outside attending physician is not authorized to perform the encounter; it must be a hospice physician or hospice nurse practitioner.

Can it be done by video?

Through December 31, 2027, yes, by two-way real-time audio and video for recertification purposes, unless the patient is in a moratorium area, the hospice is under enhanced oversight, or the clinician is not enrolled in Medicare.

Does the encounter mean my loved one is being discharged?

No. It is a routine eligibility step required before the 3rd benefit period and each one after. A stable week is not the same as recovery; the clinician documents the overall trajectory.

Practical next steps

• Ask your hospice when the next face-to-face encounter is due and whether it will be in person or by video.
• Have the caregiver present to describe recent changes.
• If a discharge is ever raised after an encounter, ask for the reason in writing and about your appeal rights.
• Choosing a provider? Compare hospices near you and ask how they schedule face-to-face visits for long-staying patients.