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CMS Home Health Face to Face Encounter for Medicare
Patient Population Impacted
Medicare and Dually-eligible Patients
Law Overview
Physician who orders homecare must see the patient within 90 days prior to the
start of homecare or within 30 days after the start of care and document specific
elements of the encounter. Based on this law, CMS requires that physicians
complete a Face to Face Encounter certification form.
Face to Face Encounter Certification form must be signed by a physician regardless of
who performs the encounter.
• Patient encounter may be performed by a physician, including hospitalist, OR by a
Non Physician Pracitioner (NPP)*.
• *A non-physician practitioner (NPP) must work for, or in collaboration with, the
physician. NPPs include:
• Nurse Practitioner
• Clinical Nurse Specialist
• Physician’s Assistant
• Employees of the MD office or hospital can transcribe appropriate clauses from the
patient record that were written by the MD to complete the Face to Face Encounter
Form but the MD must still sign the document.
Face to Face Encounter Certification includes all mandated documentation elements:
• Date of the encounter
• Encounter was related to the primary reason for homecare
• How the clinical findings support the need for intermittent skilled nursing or therapy
services
• Why the clinical findings support that the patient is homebound
• MD signature, and date of that signature
06/28/2017