More Face To Face Clarifications Issued

The following was issued by NAHC Regulatory Affairs

CMS issued an update to the Medicare Benefit Policy Manual, Pub 100-02 Chapter 7 via a Transmittal issued this afternoon at: Summarized below are new pieces of information (including exception in case of death of patient) and clarifications found in the Transmittal.

General Issues

  • The certifying physician must document that he or she or an allowed non-physician practitioner (NPP) had a face-to-face encounter with the patient.
  • Certain NPPs may perform the face-to-face encounter and inform the certifying physician regarding the clinical findings exhibited by the patient during the encounter. However, the certifying physician must document the encounter and sign the certification.
  • The documentation must include the date when the physician or allowed NPP saw the patient, and a brief narrative composed by the certifying physician who describes how the patient’s clinical condition as seen during that encounter supports the patient’s homebound status and need for skilled services on the certification or an addendum to the certification.
  • It is acceptable for the certifying physician to dictate the documentation content to one of the physician’s support personnel to type.
  • It is also acceptable for the documentation to be generated from a physician’s electronic health record.
  • It is unacceptable for the physician to verbally communicate the encounter to the HHA, where the HHA would then document the encounter as part of the certification for the physician to sign.

Exceptional Circumstances in Case of Death:

  • · When a home health patient dies shortly after admission, before the face-to-face encounter occurs, if the contractor determines a good faith effort existed on the part of the HHA to facilitate/coordinate the encounter and if all other certification requirements are met, the certification is deemed to be complete.

Hospitalist Role

  • A physician who attended to the patient in an acute or post-acute setting, but does not follow the patient in the community (such as a hospitalist) may certify the need for home health care based on his/her contact with the patient, and establish and sign the plan of care. The acute/post-acute physician would then transfer/hand off the patient’s care to a designated community-based physician who assumes care for the patient.
  • Or, A physician who attended to the patient in an acute or post-acute setting may certify the need for home health care based on his/her contact with the patient, initiate the orders for home health services, and transfer the patient to a designated community-based physician to review and sign off on the plan of care.

Return to

Author: Pat Kelleher

Pat Kelleher is Executive Director of the Home Care Alliance of Massachusetts.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: