Of the two opinions, the second one is consistent with the requirements. The examples CMS provides in the Manual about the exceptional circumstance for the timeframe do cause confusion.
By definition, an exceptional circumstance is one which is unusual, not typical. Hospices are required to make physician and nursing services available on a 24-hour basis, 7 days per week at §418.100(c)(2). Therefore, it is expected that only in an "exceptional circumstance" would a physician or NP not be available to conduct F2F encounters on weekends. There may be exceptional circumstances making the physician/NP unavailable at the time the patient needs to be admitted. These could be circumstances such as attending to another patient and another physician/NP is unavailable, an unexpected illness or absence, etc. As pointed out in the question, a patient's condition is what determines an "emergency". It is expected that these would be circumstances where the patient is experiencing symptoms that need to be addressed before a physician or NP is able to conduct the encounter. The reason for the exceptional circumstance needs to be documented in the record.
Citations:
Chapter 9, Medicare Benefit Policy Manual: In cases where a hospice newly admits a patient who is in the third or
later benefit period, exceptional circumstances may prevent a face-to-face encounter prior
to the start of the benefit period. For example, if the patient is an emergency weekend
admission, it may be impossible for a hospice physician or NP to see the patient until the
following Monday. Or, if CMS data systems are unavailable, the hospice may be
unaware that the patient is in the third benefit period. In such documented cases, a face
to face encounter which occurs within 2 days after admission will be considered to be
timely. Additionally, for such documented exceptional cases, if the patient dies within 2
days of admission without a face to face encounter, a face to face encounter can be
deemed as complete.
§418.100(c)(2) Nursing services, physician services, and drugs and biologicals (as
specified in §418.106) must be made routinely available on a 24-hour basis 7 days a
week. Other covered services must be available on a 24-hour basis when reasonable
and necessary to meet the needs of the patient and family.
------------------------------
Katie Wehri
Vice President of Regulatory Affairs, Quality & Compliance
National Alliance for Care at Home
Washington DC
+1 (202) 547-7424
kwehri@allianceforcareathome.org------------------------------
Original Message:
Sent: 01-06-2026 08:37 PM
From: Anonymous Member
Subject: Face to Face and Emergency Weekend Admission
This message was posted by a user wishing to remain anonymous
There is an ongoing discussion regarding what constitutes an "emergency" weekend admission; which would mean the required F2F could wait until Monday to be completed there are two thinking processes
1) Any admission that occurs over the weekend is considered an "emergency admission" and therefore could wait until Monday to complete the F2F
2) Admissions that occur over the weekend are not necessarily an "emergency"; an "emergency" is dictated by the patient's condition not the day of the week and therefore F2Fs need to be completed on the weekend as a standard.
Looking for insight and/or thoughts on these two opposing positions.
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