What is Hospice F2F? The face-to-face encounter

F2F, in one sentence

The hospice face-to-face (F2F) encounter is a required in-person or telehealth visit by a hospice physician or nurse practitioner to a patient prior to the recertification for the third and any subsequent benefit period, to gather clinical findings supporting continued eligibility [1].

The F2F requirement was created by the Affordable Care Act to strengthen prognostic accountability for long-length-of-stay hospice patients. It is one of the most common ADR-and-denial triggers when documentation is thin, so most compliance officers treat it as a top-priority workflow.

When the F2F must occur

• The F2F must occur no more than 30 calendar days prior to the start of the third benefit period, and no more than 30 calendar days prior to the start of every subsequent benefit period thereafter.
• The encounter can occur on any of those 30 days, including the day of the recertification itself.
• Under certain conditions (public health emergencies, specific CMS flexibilities), the encounter may be conducted via telehealth. Confirm current CMS guidance before relying on telehealth.

Benefit-period structure (see also our Benefit Period Calculator): BP1 is 90 days from admission, BP2 is 90 days from end of BP1, and BP3+ are 60-day periods thereafter. F2F applies at BP3 and every subsequent period.

Who can perform the F2F

The F2F encounter must be conducted by:

• A hospice-employed physician, OR
• A hospice-employed nurse practitioner, OR
• A physician assistant under a written collaborative agreement (following the Consolidated Appropriations Act update permitting PAs).

The attending physician (if not employed by the hospice) may NOT satisfy the F2F requirement. This is a common documentation failure.

The narrative attestation

After the encounter, the clinician who performed the F2F must write a narrative attestation that:

• Confirms the F2F occurred (date + location + who performed it).
• Provides clinical findings that support a life expectancy of 6 months or less if the disease runs its normal course.
• Is dated and signed by the clinician who performed the F2F.
• Is separate from (or clearly demarcated within) the physician certification of terminal illness.

“The patient continues to meet hospice eligibility” is not a valid F2F narrative. The narrative must include specific decline indicators — functional, nutritional, cognitive, disease-specific — observed during the encounter. Weak F2F narratives are the leading cause of hospice recertification denials on ADR review.

Common audit landmines

• Encounter conducted by the attending physician (who isn’t hospice-employed) — automatic denial.
• Encounter outside the 30-day window — even by one day — means the recertification is invalid.
• Boilerplate narrative copied across patients — MAC reviewers pattern-match these instantly.
• Missing or unsigned attestation.
• Discrepancy between F2F date and the medical record — if the physician’s note says a different date than the attestation, the record is defective.