Compliance Tip
FTF Requirements
The hospice physician or NP must attest in writing that he or she had a FTF encounter with the patient, including the date of the encounter. The attestation, which must be a separate and distinct part of the recertification, or as an addendum to the recertification associated with the 3rd benefit period, must meet the following criteria:
Clearly titled.
Accompanying signature, and date signed by the individual who performed the visit.
Date of the visit.
Clinical findings to determine continued hospice eligibility.
When the hospice NP/non-certifying physician performs the FTF, the attestation must also state that the clinical findings were provided to the certifying physician. https://www.cgsmedicare.com/hhh/coverage/hospice_ftf_encounter.html
If the Nurse Practitioner competes the FTF, the physician uses the clinical findings to determine if the patient continues to meet eligibility.
TIP: Schedule the Nurse Practitioner to conference with the IDG members prior to the FTF visit and return or document the findings in the EMR prior to the IDG meeting that the recertification is discussed and reviewed by the team. This will facilitate necessary information for the Hospice physician to determine continued eligibility.
If the Hospice physician signs, dates and certifies the patient prior to the FTF visit, the regulation is not followed and the recertification is non-compliant. This could result in a technical denial upon review.
Shelia Nelson-Meredith, The Hospice Coach
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