April 1st, 2011 marked the beginning of the new face-to-face physician encounter requirement by CMS. Under the requirements spelled out in the 2011 PPS final rule, the certifying physician must document that he or she, or a non-physician practitioner working with the physician, has seen the patient. The encounter must occur within 90 days prior to the start of the care or within 30 days after the state of care. Click on a tab to view the guidelines.
The certifying physician or qualified non-physician who is not employed by or in a financial relationship with the home health agency. Non-Physician practitioner is defined as a nurse practitioner, physician’s assistant, certified nurse midwife or clinical nurse specialist.
- The face-to-face encounter must occur no earlier than 90 days prior to the start of care or within 30 days after the start of care.
- If the face-to-face encounter occurred within 90 days of the start of care but is not related to the primary reason for home health, the non-physician practitioner or certifying physician must have a face-to-face encounter within 30 days of the start of care.
The requirement does not mandate where a face-to-face encounter must take place. In addition, Medicare telehealth visits are allowed.
- The certifying physician must document the face-to-face visit took place regardless of who performed the face-to-face encounter.
- If the face-to-face encounter was performed by the non-physician practitioner, he or she must document clinical findings and provide them to the certifying physician.
- Must be a separate and distinct section of, or addendum to, the certification.
- Documentation must include the date of the face-to-face encounter, clinical findings to support that the encounter was related to the primary reason for home care, the patient is homebound and in need of Medicare covered home health services.
- Must be a clearly titled, dated and signed by the certifying physician.
- Agencies may not formulate standard language on the certification forms related to the encounter.
The face-to-face encounter must be related to the primary reason for the home health admission.
- Social Security Act, Section 1861 (aa)(5): www.ssa.gov/op_Home/ssact/title18/1861.htm #act-1861-aa-5
- Home Health Prospective Payment Systems Rate Update for Calendar Year 2011, final rule p. 57-63: http://edocket.access.gpo.gov/2010/pdf/2010-27778.pdf
- Cahaba GBA’s Home Health & Hospice Medicare A. Newsline, Dec. 1, 2010, p 32-35: www.cahabagba.com/rhhi/news/newsletter/201012_rhhi.pdf