Home Health Face-to-Face Encounter
As a condition for payment, the Affordable Care Act mandates that prior to certifying a patient’s eligibility for the home health benefit, the certifying physician must document that he or she, or a qualified nonphysician practitioner (NPP), has had a face-to-face encounter with the patient. For initial home health certifications, the certifying physician must document that the physician, a qualified nonphysician practitioner (NPP), or a physician caring for the patient in an acute or post-acute facility, who has privileges at the facility, had a face-to-face encounter with the patient.
The initial (start of care) certification must include documentation that an allowed physician or nonphysician practitioner (NPP) had a face-to-face encounter with the patient. The face-to-face encounter must be related to the primary reason for the home care admission. This requirement is a condition of payment. Without a complete initial certification, there cannot be subsequent episodes. Claims may be denied if the face-to-face documentation is not complete.
Prior to April 1, 2011
There was no requirement for the face-to-face.
April 1, 2011, through December 31, 2014
- Face-to-face occurs 90 days prior to start of care or up to 30 days after start of care
- Encounter date must be on the document
- Document must be titled “Face-to-face”
- Narrative that addresses need for skilled services and homebound status; not required to be a clinical note
- Related to primary reason for home health services
- Performed by a physician or allowed nonphysician practitioner
- Signed and dated by physician prior to billing Medicare
January 1, 2015, to Present
- Encounter date within 90 days prior to start of care or up to 30 days after start of care
- Encounter needs to be related to primary reason for home health
- Encounter performed by a physician (M.D., D.O., DPM) or allowed nonphysician practitioner (NP, PA, CNS)
- In need of skilled nursing care on an intermittent basis or physical therapy or speech-language pathology, or have a continuing need for occupational therapy
- Certifying physician or nonphysician practitioner (effective March 1, 2020) must document the date of the face to face encounter
- Document does not have to say face-to-face when start of care is on or after January 1, 2015
Time Frame for the Face-to-Face Encounter
The face-to-face encounter must occur within 90 days prior to the start of care (SOC) or 30 days after the SOC. The face-to-face documentation must show the face-to-face encounter occurred within this timeframe.
Who Performs and Signs the Face-to-Face Encounter?
The face-to-face encounter must be performed by the certifying provider, a physician or qualified nonphysician practitioner (NPP) who cared for the patient in an acute or post-acute facility directly prior to being admitted to home health, and who had privileges at the facility, or a qualified NPP working in conjunction with the certifying physician. Only the certifying provider can attest to the date of the encounter on either the certification, or a signed addendum to the certification.
Face-to-Face Documentation
The certifying provider’s and or the acute/post-acute care facility’s patient medical record must contain information justifying referral for Medicare home health services. This includes documentation that substantiates the need for:
- Need for skilled services
- Homebound status
The certifying provider’s and or the acute/post-acute care facility’s patient medical record must contain the actual clinical encounter note that demonstrates:
- The encounter occurred within the required timeframe;
- Was related to primary reason patient requires home health services;
- Was performed by an allowed provider; and
- The document does not have to be titled or indicate “face-to-face”
This information can be found most often in (but not limited to) clinical and progress notes, discharge summaries and comprehensive assessments. The certifying provider must incorporate, by signing and dating, any documentation from the acute/post-acute care or the home health agency that is used for the basis of certification.
The face-to-face clinical encounter must be related to the primary reason for home health. The condition must be addressed within the encounter. A listing of diagnosis and medication will not meet the requirement. Medical Review nurses utilize clinical judgement for the synthesis of the clinical documentation. Etiology and causative conditions are taken into consideration when the face-to-face documentation is sufficient to demonstrate the condition. The plan of care and interventions should address the etiology (code first diagnosis) as well as any other pertinent diagnoses.
Telehealth
As of March 1, 2020, telehealth was expanded to remove the limitation of access and location to all. The encounter must be in real time and utilize two-way audio and visual components.
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