For physicians who work in collaboration with a nurse practitioner or a clinical nurse specialize, or who supervise a physician's assistant, the face-to-face encounter may be carried out by that non-physician practitioner who must document the clinical findings.
Only a physician, however, may:
- Order home health services
- Certify that a face-to-face encounter has occurred
- Certify that other eligibility criteria are met, such as medical necessity and homebound status.
The Face-to-Face Encounter Must
- Be made by the physician responsible for certifying home health (or non-physician practitioner — nurse practitioner or clinical nurse specialist in consultation with the physician, or a physician's assistant supervised by the physician.)
- Be related to the primary reason for which the patient requires home health services.
- Be made with 90 days prior to, or with 30 days of, the start of care.
Physician Documentation Requirements
Documentation of the face-to-face encounter must be a separate and distinct section of, or an addendum to, the certification. It must be clearly titled, dated and signed by the certifying physician.
Download the face-to-face documentation form
The physician must include the following information about the face-to-face encounter:
- Date of the encounter
- Indication that the encounter was related to the primary reason for home health care
- An explanation of why the clinical findings of the encounter support the need for either intermittent skilled nursing services or therapy services
- An explanation of why the clinical findings of the encounter support that the patient is homebound
- The physician's signature and date signed.
New CMS Hospice Regulations
The face-to-face encounter defined above applies to patients on home care or palliative care. For hospice patients, the hospice Medical Director or Nurse Practitioner will need to make a face-to-face encounter with hospice patients before the third or any subsequent re-certification periods. The BVNAH hospice medical director or nurse practitioner will visit patients for face-to-face encounters prior to the end of the patient's third re-certification period and then will communicate with the physician regarding their assessment.