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January 6, 2016 – Updated 09.05.24

CERT Error: Home Health Face-to-Face Encounter

Based on a review of Comprehensive Error Rate Testing (CERT) errors, home health agencies (HHAs) did not send sufficient documentation to support a face-to-face (FTF) encounter in response to the CERT contractor's request for medical record documentation. Specifically, providers submitted a form that indicates the date the FTF took place rather than the actual FTF encounter note.

Per the CMS Medicare Benefit Policy Manual (Pub. 100-02), chapter 7External PDF:

  • Section 30.5.1.2 – Supporting Documentation

    HHAs must be able to provide supporting documentation to review entities and/or CMS upon request. Such documentation from the certifying physician or allowed practitioner and/or acute or post-acute facility medical record must:

    • Support the certification of the patient's eligibility for the Medicare home health benefit
    • Contain the actual clinical note for the FTF encounter visit that demonstrates 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.

  • Section 30.5.1.2 – Face-to-Face Encounter

    • As part of the certification of a patient's eligibility for the Medicare home health benefit, a FTF encounter with the patient must be performed by:
      • The certifying physician or allowed practitioner himself or herself,
      • A physician or allowed practitioner that cared for the patient in the acute or post-acute facility (with privileges who cared for the patient in an acute or post-acute care facility from which the patient was directly admitted to home health), or
      • An allowed non-physician practitioner (NPP).
    • The encounter must occur no more than 90 days prior to the home health start of care date or within 30 days after the start of care.

If the CERT contractor requests medical record documentation for home health services, please ensure you send complete FTF documentation. For start of care (SOC) and subsequent episodes, this might include, but is not limited to, the actual clinical notes (e.g., discharge summary, history & physical, progress notes, or physician office visit note) for the primary reason the beneficiary was referred to homecare. In addition, submit the initial home health SOC plan of care and any certifying physician attestations with every episode.

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