F2F Attestation Requirement Has Existed Since 2011 -
Since 2011, hospice physicians or nurse practitioners have been required to complete a F2F encounter as part of the third and later benefit period recertification...more
1/9/2026
/ Attestation Requirements ,
Centers for Medicare & Medicaid Services (CMS) ,
Certification Requirements ,
Compliance ,
Final Rules ,
Health Care Providers ,
Healthcare ,
Hospice ,
Medical Records ,
Medicare ,
Nurse Practitioners ,
Regulatory Requirements ,
Reporting Requirements ,
Statutory Authority
Medicare provider enrollment and the infamous CMS 855 Form rarely make for headline-grabbing topics. Nevertheless, the consequences of mismanaging your Medicare provider enrollment record can be severe, including deactivation...more
12/30/2025
/ Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Enrollment ,
Filing Deadlines ,
Health Care Providers ,
Healthcare ,
Healthcare Facilities ,
Medicare ,
Policies and Procedures ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
The world of Medicare enrollment and the 855 may seem like a tangle of boring paperwork, but all that i-dotting and t-crossing is critical for avoiding Medicare deactivation and other unpleasant consequences. In this episode,...more
CMS’s FY 2026 hospice final rule introduces significant changes to the face-to-face (F2F) attestation requirements starting October 1, 2025. All in all, the news is positive: while there is a new requirement for the F2F...more
The hospice industry saw many regulatory changes in 2023. In this episode of Hospice Insights: The Law and Beyond, Husch Blackwell's Meg Pekarske, Andrew Brenton, and Adam Royal discuss some of the main regulatory changes...more
Earlier this spring, as part of its annual rulemaking process for hospices, the Centers for Medicare and Medicaid Services (CMS) issued several important regulatory proposals. In addition to the yearly update in hospice per...more
The HIPAA regulations require that covered entities enter into agreements with business associates who provide certain services for the covered entity involving the receipt, use, or disclosure of protected health information....more
The U.S. Department of Health and Human Services’ Office of Inspector General (OIG) reported in November 2022 that many providers are not complying with Medicare’s billing rules for advance care planning services. In large...more
While direct patient billing may be less common for hospice patients than for patients receiving hospital or other types of care, there are aspects of the No Surprises Act and its implementing regulations that are important...more
The hospice physician plays an enormously critical role in hospice operations, from certifying patients as terminally ill to being the hospice’s representative in the community. Just as the physician’s role is critical, so...more
The hospice certification of terminal illness is one of the documents most scrutinized by Medicare contractors, and it is of critical importance since an invalid certification can impact Medicare payment for the patient’s...more
The hospice election may be the single most important document for hospices since an invalid form can impact payment for a patient’s entire stay. Especially in light of a recent rise in Medicare claim denials related to the...more
For the last two-and-a-half years, hospices and other providers have been using billions in Provider Relief Fund (PRF) payments to prepare for, respond to and recover from the COVID-19 pandemic. The Office of Inspector...more
When confronted with a complaint, allegation or event that implicates a potential Medicare overpayment, hospices have an affirmative duty under the federal 60-day repayment rule to conduct an investigation and refund any...more
In this era of disruption and market consolidation, the talk of the town is how hospices can make strategic pivots to expand their geography, diversify the scope of their services to get further upstream, and otherwise be...more
In a follow-up to its recent reports on billing outside the hospice benefit for drugs and durable medical equipment (DME), the Office of Inspector General’s (OIG) new data report identifies billions being billed to Medicare...more
Private payor contracts will define future revenue for hospices. Whether it be Medicare Advantage Value-Based Insurance Design (VBID) contracts for hospice services or for upstream non-hospice services (palliative and...more
By October 1, 2021, hospices will need to update their election addendum form to address a change made by the Centers for Medicare & Medicaid Services (CMS) in the final rule. The government has provided much-needed...more
The “rules of the road” for Provider Relief Funds continue to evolve. Recent actions by Congress and the U.S. Department of Health and Human Services provide further clarification in key areas that are helpful to hospices. In...more
September was another busy month as hospices and other providers try to keep pace with the government’s constantly evolving rules and standards around various COVID-19 federal relief programs. In this episode of Hospice...more
On September 19, 2020, the U.S. Department of Health and Human Services (HHS) released long-awaited details about upcoming reporting requirements for certain providers that accepted funding of one or more payments exceeding...more
The hospice industry expressed collective disappointment when the Centers for Medicare & Medicaid Services declined additional time for implementing new election statement and addendum requirements. On October 1, 2020,...more
8/21/2020
/ Addendums ,
Centers for Medicare & Medicaid Services (CMS) ,
Conditions of Payment ,
Health Care Providers ,
Hospice ,
Medicaid ,
Medicare ,
New Rules ,
Training ,
Updated Forms ,
Wage Index
Under new guidance from the U.S. Department of Health and Human Services (HHS), hospices and other providers who received CARES Act Provider Relief Fund payments can hold off on filing their first quarterly compliance report,...more
Under new guidance from the U.S. Department of Health and Human Services (HHS), hospices and other providers who received CARES Act Provider Relief Fund payments can hold off on filing their first quarterly compliance report,...more
After the U.S. Department of Health and Human Services (HHS) automatically distributed $30 billion to providers as Tranche #1 Relief Fund payments based on 2019 Medicare fee-for-service payment data, HHS subsequently released...more