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3 Things You Need to Know About Face-to-Face Encounters

by Blair Stokes

Medicare’s Face-to-Face requirement is basically the moody teenager of home health care regulations, lamenting “you just don’t understand!” While most teens eventually outgrow being misunderstood, the Face-to-Face encounter continues to be one the most complex and confusing issues in the industry. Continually changing requirements have home health care providers scratching their heads and asking questions like,

  • When is a form required?
  • In what cases do you need a physician signature?
  • What kinds of supporting documentation are required?
  • Who can perform the Face-to-Face encounter?

Home health thought leader Arlene Maxim, RN of QIRT (Quality in Real Time) answers these questions and more in a new frequently asked questions tip sheet. Here are three key takeaways from Arlene’s insights to help you better understand Face-to-Face:

  1. A Face-to-Face form is no longer required. Reviewers look at the information, but the form itself will not assist compliance with the rule. In fact, the Medicare Administrative Contractors (MACs) will not use a “Face-to-Face form” as evidence of the encounter. Agencies must secure progress notes from physicians or, in the case of an inpatient referral, Face-to-Face documentation from the inpatient practitioner — non-physician provider (NPP) or physician. The agency may supplement information, as noted below.​
  2. You probably know that physicians can complete the Face-to-Face encounter, but so can qualifying non-physician providers (NPPs). Five roles can perform Face-to-Face encounters: 
    1. The certifying physician 

    2. A physician, 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

    3. A nurse practitioner or a clinical nurse specialist who is working in accordance with state law and in collaboration with the certifying physician or in collaboration with an acute or post-acute care physician with privileges who cared for the patient in the acute or post-acute care facility from which the patient was directly admitted to home health

    4. A certified nurse midwife, as authorized by state law, under the supervision of the certifying physician or under the supervision of an acute or post-acute care physician with privileges who cared for the patient in the acute or post-acute care facility from which the patient was directly admitted to home health

    5. A physician assistant under the supervision of the certifying physician or under the supervision of an acute or post-acute care physician with privileges who cared for the patient in the acute or post-acute care facility from which the patient was directly admitted to home health

  3. Anything the agency can supply as far as supportive documentation deeming the patient eligible is acceptable. According to CMS, “information from the HHA, such as the patient’s comprehensive assessment, can be incorporated into the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient.” This means that agencies can input documentation –– if signed and incorporated into the physician records –– that supplies information missing from the Face-to-Face encounter note. CMS also notes, “information from the HHA must be corroborated by other medical record entries and align with the time period in which services were rendered.”

Like a moody teen, Face-to-Face is something home health providers will have to deal with as it continues to grow and change over time. In the meantime, Kinnser has developed plenty of educational materials to help you stay in compliance.

Download free resources here:

Read more in: Administration, Clinical, Coding

About Kinnser software

Kinnser Software, Inc. provides web-based solutions that deliver clinical and business results to the home health, hospice and private duty industries. Founded in 2003 and headquartered in Austin, Texas, Kinnser Software serves more than 4,000 home health, therapy, hospice, and private duty home care providers nationwide. Kinnser helps thousands of clinicians and other staff in post-acute healthcare to manage scheduling, billing, electronic visit verification, day-to-day operations, and patient referrals. 

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