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Home Health Face-to-Face Encounter

The initial (Start of Care) certification must include documentation that shows an allowed physician or non-physician practitioner (NPP) had a face-to-face (FTF) encounter with the patient related to the primary reason for the home care admission. This requirement is a condition of payment. If the initial certification and FTF documentation is incomplete, subsequent episodes aren't covered and claims may deny.

Timeframe

Documentation must show that the FTF encounter occurred within 90 days before or 30 days after the Start of Care (SOC) date.

Who Performs & Signs

One of the following providers must perform the FTF encounter with the patient:

  • The certifying physician or a physician with admitting privileges who provided care to the patient in an acute or post-acute care facility before the patient's direct admission to home health services
  • The certifying nurse practitioner or clinical nurse specialist, or a nurse practitioner or clinical nurse specialist practicing in accordance with state law, and in collaboration with a physician or acute or post-acute care physician with privileges, who treated the patient in the facility from which the patient was directly admitted to home health services

When a beneficiary is admitted from home or a community setting, and the certifying and FTF performing providers are different, a community provider (including one who isn't the certifying provider) can perform the FTF encounter if the following conditions are met:

  • The documentation contains evidence that the certifying provider collaborated with the provider who performed the FTF before the certification.
  • It's evident that the certifying and FTF providers are part of the same practice (documentation of collaboration isn't required).

FTF Documentation

Documentation in the certifying physician or acute/post-acute care facility medical records (when the patient is directly admitted to home health) is used to determine patient eligibility for the Medicare home health benefit.

To be eligible for the home health benefit, a physician must certify that the patient meets the following requirements:

  • Confined to the home;
  • Under the care of a physician or allowed practitioner;
  • A plan of care is established and periodically reviewed by a physician or allowed practitioner; and
  • Services are furnished while the patient is under the care of a physician or allowed practitioner.

A home health agency's generated medical record documentation alone isn't sufficient to demonstrate the patient's eligibility for the home health benefit. To help support the FTF, home health documentation (i.e., admit summary, part of the OASIS or therapy evaluation/notes, nurse's notes) that supports the certification must include the certifying physician's signature and be incorporated into the physician or acute/post-acute care facility medical record. Documentation must also correspond with the dates of service billed and not contradict the certifying physician's or acute/post-acute care facility's own documentation or medical record entries.

Documentation from the certifying physician or acute/post-acute care facility medical records (when the patient is directly admitted to home health) used to support the certification of home health eligibility must be provided to the home health agency, review entities, or CMS upon request.

The certifying physician or acute/post-acute care facility medical record (when the patient is directly admitted to home health) for the patient must contain the actual clinical note for the FTF encounter visit that demonstrates that the encounter:

  • Occurred within the required timeframe,
  • Is related to the primary reason the patient requires home health services; and
  • Is performed by an allowed provider type.

This information is often found in clinical progress notes and discharge summaries.

Billing Responsibilities

As the billing entity, the home health agency is responsible for:

  • Facilitation and coordination between the patient and physician to ensure the FTF occurs timely;
  • Ensuring all FTF requirements are met;
  • Delaying the final claim submission until all FTF and documentation requirements are met.

Additional Resources

Updated: 08.13.2026
Reviewed: 08.13.2026

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