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Regulations Require Physician Face-to-Face Patient Encounters

New Centers for Medicare & Medicaid Services (CMS) regulations implemented in 2011 require that patients referred to home health agencies must have a face-to-face encounter with the physician who certifies home care either 90 days before or within 30 days of the start of home care services.  The regulation also specifies that the physician must address the primary reason for home services during this encounter.

 

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.