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In this Question of the Week, Melinda Gaboury, CEO answers a question related to Hospice Face-to-Face Visits.

Q: For face-to-face visits, it was mentioned that APRNs/NPs need to be PECOS enrolled.  Currently all our APRNs are enrolled in HHH and DME but there was no enrollment option for hospice. Will this be changing and will they need to enroll specifically for hospice?  Also, can you clarify if there is ever a time that a face-to-face cannot be via telehealth under the current rules?

A: The APRN/NPs just have to be in PECOS marked as HH. They will not be listed under hospice until the regulations change allowing NPs to certify hospice patients.  The only times you cannot use the telehealth face-to-face encounter in hospice is when:

  • It is conducted by an APRN/NP that is not in PECOS
  • It is not conducted on a HIPAA compliant platform
  • The encounter was not both audio and video.
  • If your agency were to currently be under a PPEO audit you would not be able to accept telehealth F2F.

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