If you bill for an episode without all the required face to face encounter documentation, you are asking for trouble. Once the April 1 enforcement date for the new FFE mandate arrives, you'll have to eat the episode's cost when a FFE doesn't occur. So says a recently update Frequently Asked Question on the topic from the Centers for Medicare & Medicaid Services. Question: "If a patient has a face-to-face encounter on day 33 after the start of care, will the HHA be denied payment for services provided from day 1 through day 30?" a provider asked. Answer: "If the certification content requirements are not complete, the agency cannot bill," CMS responds. That includes the FFE requirements covering the visit and documentation.