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Home Health Face-to-Face (FTF) Encounter

The initial (Start of Care) certification must include documentation that an allowed physician or non-physician practitioner (NPP) had a face-to-face (FTF) encounter with the patient. The FTF encounter must be related to the primary reason for the home care admission. This requirement is a condition of payment. Without a complete initial certification, there cannot be subsequent episodes. Claims may be denied if the FTF documentation is not complete.

Time Frame for the Encounter

The FTF encounter must occur within 90 days prior to the Start of Care (SOC) or 30 days after the SOC. The FTF documentation must show the FTF encounter occurred within this timeframe.

Who Performs and Signs the FTF Encounter

The FTF encounter must be performed by the certifying physician, a physician who cared for the patient in an acute or post-acute facility directly prior to being admitted to home health, and who had privileges at the facility, or a qualified non-physician practitioner (NPP) working in conjunction with the certifying physician. An NPP in an acute or post-acute facility from which the patient was directly admitted to home health is able to perform the FTF encounter in collaboration with or under the supervision of the physician who had privileges and cared for the patient in the acute or post-acute facility. Only the certifying physician can attest to the date of the encounter on either the certification, or a signed addendum to the certification.

FTF Documentation

As of January 1, 2015, documentation in the certifying physician's medical records and/or the acute /post-acute care facility's medical records (if the patient was directly admitted to home health) will be used as the basis upon which patient eligibility for the Medicare home health benefit will be determined.

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

  • Be confined to the home;
  • Under the care of a physician;
  • Services are provided under a plan of care established and periodically reviewed by a physician;
  • Be in need of skilled nursing care on an intermittent basis or physical therapy or speech-language pathology; or
  • Have a continuing need for occupational therapy.

The home health agencies generated medical record documentation, by itself, is not sufficient in demonstrating the patient's eligibility for the home health benefit. Therefore, home health documentation such as, an admit summary, part of the OASIS, or a therapy evaluation/therapy notes, nurses notes that support the certification must be signed off by the certifying physician and incorporated into the physician or acute/post-acute care facility's medical record to help support the FTF. Documentation must correspond to the dates of service being billed and not contradict the certifying physician's and/or the acute/post-acute care facility's own documentation or medical record entries.

Documentation from the certifying physician's medical records and/or the acute /post-acute care facility's medical records (if the patient was directly admitted to home health) used to support the certification of home health eligibility must be provided, upon request, to the home health agency, review entities, and/or the Centers for Medicare and Medicaid Services (CMS).

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

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

This information can be found most often in clinical and progress notes and discharge summaries.

Billing Responsibilities

As the billing entity, it is the responsibility of the home health agency to:

  • Facilitate and coordinate between patient and physician to ensure the FTF occurs timely;
  • Ensure all FTF requirements are met;
  • Delay submission of the final claim until all FTF requirements and documentation is met.

Additional Resources

Updated: 11.29.18

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