Government Shutdown Impacts Hospice Providers: Telehealth Face-to-Face Encounters Expired
- Joshua Simpson
- Oct 1
- 3 min read
The recent government shutdown has created serious challenges for hospice providers, particularly with the expiration of the Hospice Face-to-Face (F2F) Telehealth flexibility. Starting October 1, 2025, all hospice F2F encounters will need to meet pre-pandemic standards, which means that physicians or nurse practitioners must conduct these visits in person. This change results from Congress's failure to pass a Continuing Resolution, eliminating Telehealth options that providers have relied on during the pandemic.
In this blog post, we will examine how this shutdown affects hospice providers, focusing on F2F encounter requirements, delays in iQIES/HOPE Tool support, Telehealth billing challenges, controlled substance prescribing, and actionable strategies for hospice agencies to manage this transition successfully.
Face-to-Face Encounters
The Face-to-Face encounter requirement is a key part of hospice care, dictated by 42 CFR §418.22(4)(i). This regulation requires that a qualified physician or nurse practitioner conduct F2F encounters to evaluate patient eligibility for hospice services. With the end of Telehealth flexibility, all F2F encounters must now take place in person, which poses difficulties for many agencies that have adapted to virtual assessments.
The need for in-person visits presents logistical challenges, especially in areas where providers are limited. For instance, studies show that about 20% of hospice providers in rural regions have faced difficulties reaching their patients due to transportation issues. Hence, hospice agencies must strictly comply with these regulations to avoid penalties and ensure patient care continuity. It is essential to note that the Centers for Medicare & Medicaid Services (CMS) will not allow leniency regarding these requirements, and there will be no retroactive payments for missed encounters.
iQIES/HOPE Tool Support Delays During the Shutdown
The government shutdown has also caused delays in support for critical resources like the iQIES (Internet Quality Improvement and Evaluation System) and the HOPE (Hospice Outcomes and Patient Evaluation) Tool, which subsequently took effect the same day, October 1, 2025. These tools help hospice providers report quality measures essential for meeting federal guidelines. During this shutdown, hospice agencies may face challenges accessing these resources, which can hamper their ability to remain compliant.
Additional Impacts for Hospice & Palliative Care Providers
Telehealth Part B Billing
The home is no longer considered an originating site. Telehealth encounters must now take place in a facility such as a hospital, skilled nursing facility (SNF), or physician's office.
Geographic restrictions have been reinstated, which limits Telehealth services to rural Health Professional Shortage Areas (HPSAs), non-Metropolitan Statistical Areas (non-MSA) counties, or designated demonstration project areas.
Two-way, interactive audio-video technology is now a requirement for all Telehealth services.
Specific practitioners—including Occupational Therapists (OTs), Physical Therapists (PTs), Speech-Language Pathologists (SLPs), and audiologists—are now excluded from providing Telehealth services under Part B.
Controlled Substance Prescribing
This area is not affected by the shutdown. The DEA's separate rule continues to allow Telehealth prescribing flexibilities through December 31, 2025.
Action Steps for Hospice Agencies
To navigate the recent challenges posed by the government shutdown, hospice agencies should consider taking the following proactive steps:
Audit Recertifications: Review and complete patient recertifications to ensure all F2F encounters meet the new in-person requirements before deadlines.
Notify Providers: Inform all healthcare providers involved in hospice care about the updated F2F encounter requirements, focusing on the importance of in-person visits.
Update Policies/EMRs: Revise internal policies and electronic medical records (EMRs) to reflect the new requirements for F2F encounters, ensuring that all staff receive training on these changes.
Plan for iQIES Delays: Prepare for potential delays in iQIES and the HOPE Tool.
Communicate with Staff and Families: Keep staff informed about the changes in hospice care delivery and emphasize the importance of in-person visits for F2F encounters to families and caregivers.
Final Thoughts
The government shutdown has created immediate compliance risks for hospice providers. The loss of Telehealth flexibility for F2F encounters—combined with the simultaneous launch of the HOPE tool and limited iQIES support—means agencies must act quickly to stay compliant.
For more information or assistance, feel free to contact 435-799-5827 or josh.simpson@hccsgroup.net.
