Who Can Do the Face-to-Face Encounter for Home Health?

Medicare won’t pay home health agencies to care for Medicare patients without a physician’s certification. For initial home health certifications, the physician must document there has been a face-to-face encounter with the patient.

The following may perform the face-to-face encounter:

  • A Medicare-enrolled physician who is also the certifying physician and who does not have a financial relationship with the home health agency.
  • A physician (Medicare-enrolled or otherwise) who cared for the patient in an acute or post-acute facility during a recent acute or post-acute stay. This physician can perform the face-to-face encounter and then must communicate to the certifying physician that the face-to-face encounter supports the Medicare home health eligibility. The certifying physician may use use the encounter documentation from the acute/post-acute physician as his or her documentation of the face-to-face encounter.
    • The acute/post-acute physician must have privileges at the acute or post-acute facility, or
    • If the other physician is a resident — because residents do not have privileges at acute or post-acute facilities — he or she must act under the supervision of a teaching physician who must have such privileges.  
  • A nonphysician practitioner (NPP) — nurse practitioner, clinical nurse specialist, certified nurse-midwife, or physician assistant — subject to physician collaboration and supervision requirements. NPPs also are subject to the same financial restrictions regarding the home health agency as a certifying physician. 

For more information about certifying Medicare patients for home health services, see the Centers for Medicare & Medicaid Services' (CMS') MLN Matters No. SE1219 (PDF) ("A Physician’s Guide to Medicare’s Home Health Certification, including the Face-to-Face Encounter") and CMS' Home Health Face-to-Face Encounter Question & Answers (PDF). Be sure to read about changes to documentation requirements for home health care episodes beginning on or after Jan. 1, 2015: MLN Matters No. MM9119 (PDF).

Revised April 21, 2015



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