An FFE mistake could leave you holding the payment bag. 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.