Home Health & Hospice

Check out Homecare and Hospice Requirements for Face-to-face Encounter

Homecare Insider, August 30, 2010

The proposed rule to update the Prospective Payment System (PPS) presents many challenges.  The rule includes a requirement for a face-to-face encounter for both homecare and hospice patients.  On the homecare side, the physician and patient must have a face-to-face encounter within 30 days before or two weeks after the start of homecare services.  Here are a few facts from the proposed rule.

  • The attending physician, the one who will sign the initial certification (plan of care), or a nurse practitioner or physician assistant under the supervision of the physician, must see the patient or conduct this encounter through telehealth. 
  • The reason for the encounter must relate to the reason for home health services. 
  • If done by a non-physician practitioner, he or she must document the encounter and communicate the findings to the physician.
  • The physician must document the findings of the encounter on a separate and distinct section of the plan of care or addendum. 
  • This documentation must connect the condition being treated during the encounter with the reason for home health services, as well as support the patient’s homebound status and qualifications for Medicare coverage.
  • The statement must be clearly titled, dated, and signed. 


On the hospice side, a hospice physician or nurse practitioner must visit each hospice patient no more than 15 calendar days prior to the 180-day recertification and each successive recertification after that.  The encounter must gather findings to support the patient’s eligibility for hospice care.  The Centers for Medicare and Medicaid Services (CMS) notes that this requirement applies to “each hospice patient, whose total stay across all hospices is anticipated to reach 180 days.”  Documentation of the encounter must be on a separate and distinct section of the recertification form or addendum and be clearly title, signed, and dated.

Remember, the deadline for submitting comments on provisions of the rule is September 14.  Download the proposed rule at — http://edocket.access.gpo.gov/2010/pdf/2010-17753.pdf.  Stay-tuned for more guidance from CMS.