Recertification Face-to-Face Requirements

A recertification face-to-face (FTF) encounter is a required in-person clinical visit that a hospice physician or hospice nurse practitioner must conduct before a patient's third benefit period and before every benefit period thereafter, to gather the clinical findings that support continued hospice eligibility (42 CFR 418.22(a)(4), https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-418/subpart-B/section-418.22).

The encounter must occur prior to, but no more than 30 calendar days prior to, the start of the third benefit period recertification and every benefit period recertification thereafter (42 CFR 418.22(a)(4), https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-418/subpart-B/section-418.22). Only a hospice physician or a hospice nurse practitioner may perform it; a physician assistant may serve as an attending physician but may not conduct the recertification FTF. The clinician must complete an attestation — a separate, distinct section of the recertification, an addendum, or a clinical note — stating that the encounter occurred and including the clinical findings, the date of the visit, the signature of the physician or NP who conducted it, and the date of signature. When a nurse practitioner performs the encounter, the NP attests that the clinical findings were provided to the certifying physician for use in recertifying the six-month prognosis. The regulation originally authorized telehealth for the recertification FTF through September 30, 2025 (42 CFR 418.22(a)(4), https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-418/subpart-B/section-418.22). Congress subsequently extended the allowance: the Consolidated Appropriations Act, 2026 (H.R. 7148, signed February 3, 2026) extends telehealth for hospice recertification face-to-face encounters through December 31, 2027 ^[1]. Two new restrictions apply under the CAA 2026: beginning January 31, 2026, telehealth may not be used for the recertification FTF if the patient is located in an area subject to a hospice enrollment moratorium or is receiving care from a hospice under enhanced oversight; and beginning January 1, 2027, hospices must report telehealth FTF encounters on the claim using specified modifiers (CMS Hospice Center)^[2]. The FY2027 final rule (CMS-1851-F, July 30, 2026) finalizes conforming regulation text changes to the hospice telehealth face-to-face policy under the CAA 2026 (CMS FY2027 final rule fact sheet)^[3].

The FTF is a hard billing gate, not a documentation nicety. Miss the 30-day window, or use an unqualified clinician such as a physician assistant, and the entire benefit period is non-covered — every day, not just the visit. The highest-risk scenario is a patient transferring between hospices near the third benefit period, where the receiving hospice inherits the timing obligation and often discovers the gap after the fact. Because the encounter must precede the period, a late FTF cannot be cured retroactively; the days are lost and must be self-reported. The encounter's strict pre-period timing means the recertification workflow must include a trigger no later than 30 days before the period start, and the performing clinician's credential must be verified before the visit occurs.