Hospice MD/designee/IDG physician PLUS attending physician (if patient has one)
No
2nd
90 days
Hospice MD/designee/IDG physician only
No
3rd
60 days
Hospice MD/designee/IDG physician only
Yes - within 30 days before period start
Each subsequent 60-day
60 days
Hospice MD/designee/IDG physician only
Yes - within 30 days before period start
Required Certification Content (Every Period)
No templated narratives. CMS requires a patient-specific narrative describing the individual's clinical trajectory and prognosis-supporting findings. Copied boilerplate is a high-frequency denial trigger in medical review.
Required Element
Operational Requirement
Common Failure
6-month prognosis statement
States prognosis of ≤6 months if illness runs normal course
Generic language without patient context
Patient-specific narrative
Individual clinical findings supporting prognosis
Templated or copied from prior period
Supporting clinical information
In record; may initially be verbal but must be documented
Narrative present; no corresponding chart documentation
Physician signature and date
All certifications signed and dated by certifying physician(s)
Unsigned; missing signature date (FY 2026 rule)
Benefit period dates
Specific start and end dates included in certification
Missing dates; dates misaligned to election timeline
Face-to-Face Encounter (3rd+ Benefit Periods)
Rule
Requirement
Authority
Who may conduct
Hospice physician or hospice NP only - NOT the attending
42 CFR 418.22(a)(4)
Timing window
Within 30 calendar days before the benefit period being recertified
42 CFR 418.22(a)(4)
Attestation must include
Encounter date, practitioner signature, AND signature date (FY 2026 restored)
42 CFR 418.22(b)(4); FY 2026 Final Rule
Telehealth authority
Verify current CMS guidance - limited statutory extension; not permanent
CMS Hospice Center guidance
Certification Timing Quick Rules
Written certification: Must exist before claim submission
Oral exception: If written cert unavailable within 2 calendar days of period start - oral certification within 2 days; written before claim submission 42 CFR 418.22(a)(3)(i)
Early completion limit: No more than 15 calendar days before benefit period start date 42 CFR 418.22(a)(3)(ii)
Claim denial risk: Certification that does not meet timing rules is not merely a survey deficiency - missing or late certification results in claim denial for the entire benefit period until a compliant certification is obtained.
Educational Use Only. Not legal advice. Verify against current primary sources.