Hospice Recertification Requirements: Timing, Documentation, and Face-to-Face Encounters

Short answer: A hospice physician must recertify the patient’s terminal illness for each benefit period. The certification must be supported by the patient’s medical record and an individualized physician narrative. Before the third benefit period and each later period, a hospice physician or nurse practitioner must also complete a face-to-face encounter within the required timeframe. The physician remains responsible for certifying the terminal illness.^[1][2]

How are Medicare hospice benefit periods structured?

The Medicare hospice benefit begins with two 90-day periods, followed by an unlimited number of 60-day periods. A physician must certify or recertify that the patient is terminally ill for each period. Continued coverage depends on the patient continuing to meet the eligibility requirements and the hospice completing the required certification and documentation.^[2][3]

What must the recertification record contain?

The certification or recertification must include the physician’s statement that the patient is terminally ill, the applicable benefit-period dates, required physician signature and date, and clinical support for the prognosis. The physician’s narrative should explain the specific clinical findings supporting a life expectancy of six months or less if the illness runs its normal course. CMS requires an individualized narrative that reflects the patient’s circumstances, not a standard statement repeated from case to case.^[1][2]

A recertification may be completed no more than 15 calendar days before the start of the next benefit period. The team should make the supporting records available to the physician and preserve the dates and documentation associated with the certification.^[2]

When is the face-to-face encounter required?

A hospice physician or nurse practitioner must have a face-to-face encounter with the patient before the start of the third benefit period and before every later benefit period. The encounter must generally take place no more than 30 calendar days before the recertification. The third and later benefit-period narrative must explain how the clinical findings from that encounter support the physician’s prognosis.^[1][2]

A nurse practitioner may conduct the face-to-face encounter but may not certify or recertify the terminal illness. A physician must complete that certification. CMS guidance allows a signed and dated clinical note to fulfill the face-to-face attestation requirement when it clearly identifies that the encounter occurred and includes the encounter date, practitioner signature, and signature date.^[1]

Can a face-to-face encounter be completed by telehealth?

CMS has extended telehealth use for hospice face-to-face recertification encounters through December 31, 2027. The extension has eligibility and location-related limits, so agencies should check the current CMS instructions before scheduling or billing a telehealth encounter. CMS also notes that additional claim reporting requirements apply to telehealth encounters beginning in 2027.^[4][3]

What should operations teams track?

A reliable recertification process can make the required work visible without making a clinical decision. Teams may find it useful to track:

• The current benefit period and the date the next period begins.
• When the physician’s recertification must be completed and signed.
• Whether a face-to-face encounter is required and the allowable encounter window.
• The source records and clinical findings prepared for physician review.
• Open documentation questions, follow-up owners, and the date each item is resolved.

These workflow steps do not replace current Medicare requirements, the medical record, or the physician’s independent judgment. A missing item is a prompt for follow-up, not a clinical conclusion about eligibility.

How Aether supports recertification work

Aether helps hospice teams organize records, source-linked evidence, open questions, and review steps in a structured case workflow. It supports preparation and visibility; it does not determine eligibility, replace the medical record, or complete physician certification.

Sources

1. Centers for Medicare & Medicaid Services, Hospice Services: Medicare Provider Compliance Tips.
2. Centers for Medicare & Medicaid Services, Medicare Benefit Policy Manual, Chapter 9, section 20.1.
3. Centers for Medicare & Medicaid Services, Medicare Payment Systems.
4. Centers for Medicare & Medicaid Services, Hospice News & Announcements: Extended use of Telehealth.

This guide provides general operational information, not legal advice or a patient-specific clinical determination. CMS rules and billing instructions can change. Confirm current requirements and apply clinician judgment to each patient’s circumstances.