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Medicare Home Health Face-to-Face Encounter Requirement

The Affordable Care Act (ACA) established a face-to-face encounter requirement for certification of eligibility for Medicare home health services, by requiring the certifying physician to document that he or she, or a non-physician practitioner working with the physician, has seen the patient. The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. Documentation of such an encounter must be present on certifications for patients with starts of care on or after January 1, 2011. The regulation has been fully implemented and providers are complying with the requirements.

Certification for home health is already required by physicians. The face-to-face encounter for home health care can be included in the certification documentation or on a separate form.

More information on the home health FTF encounter requirement can be found on the CMS’ Home Health Agency (HHA) Center website.

• Frequently Asked Questions regarding the home health face-to-face encounter requirement
• Sample forms for the home health FTF encounter documentation
• Example 1
• Example 2
• Example 3
• Example 4
• A Physician’s Guide to Medicare’s Home Health Certification, including the Face-to-Face Encounter CMS Guide

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