FACE TO FACE ENCOUNTERS
What you need to know!

CMS now requires that all Medicare patients have a face-to-face encounter (in-person visit) with a qualifying practitioner either 90 days before or 30 days after their home health care admission.

CMS DEFINES A QUALIFYING PRACTITIONER AS:

• Community Physicians (i.e. PCP) who will certify the patient’s home health plan of care.
• Hospitalists may sign the attestation certifying an inpatient physician encounter, as long as they can identify the Community Physician who will be caring for the patient following discharge and who will certify the patient’s home health plan of care Residents who are certified by Medicare are also authorized to sign the attestation form. Resident must have a NPI (National Provider Identification) number
• Non-Physician Practitioners (NPP) such as a Nurse Practitioner, Clinical Nurse Specialist or Physician’s Assistant, may complete the face to face encounter and document the clinical findings on the attestation, but must have a certified physician date and sign the form.

FACE TO FACE ENCOUNTER ATTESTATION FORM MUST INCLUDE:

• The patient’s name and identification (usually date of birth).
• The date of the encounter and that the visit was related to, completely or in part, the medical condition for which the patient needs home health care services.
• Clinical findings that support the medical necessity and need for Medicare-covered skilled nursing, physical therapy and/or speech therapy services.
• Clinical findings that support the patient is homebound.

The Face to Face Encounter Attestation form must be a separate and distinct section of or addendum to the physician’s orders/485 and must be clearly signed and dated by the certifying physician who either performed the encounter or received documentation from their NPP.

A member of the physician’s staff or a discharge planner may complete the form for the physician to sign and date as long as the information concerning the encounter is extracted from the physician's (or NPP’s) own medical record entries. The entries must include how the patient's clinical condition (as seen during the encounter) supports homebound status and the need for skilled services.

If you have any questions about face to face, please do not hesitate to contact us at (617) 426-5555.

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