Face-to-Face Encounter

The encounter must occur no more than 90 days before the start of care or within 30 days after it, and it must relate to the primary reason the patient requires home health services. It can be performed by the certifying physician or allowed practitioner; by a physician who cared for the patient in the acute or post-acute facility from which the patient was directly admitted to home health; or by a nurse practitioner, clinical nurse specialist, or physician assistant working with the certifying physician under the applicable collaboration or supervision rules. When someone other than the certifying practitioner performs the encounter, the findings must be communicated to the certifying practitioner, who incorporates them into the certification.

The encounter itself is not enough; the record must prove it. The certifying practitioner documents the encounter date as part of the certification, and the medical record must show that the encounter was related to the primary reason for home health. Critically, the certifying practitioner's own records (and the acute or post-acute facility records, where applicable) must support eligibility: the agency's documentation alone cannot establish homebound status and skilled need, though agency-generated material such as the plan of care can be incorporated into the practitioner's record if the practitioner signs it. Reviewers deny claims where the encounter note is off-topic, undated, or silent on the clinical picture that justifies home health.

Since 2020, Medicare telehealth flexibilities have allowed the face-to-face encounter to be performed via telehealth, and Congress has extended those flexibilities several times rather than making them permanent. Because the authority has moved in short legislative increments, agencies should verify the current status and any modality requirements, such as audio-video versus audio-only, before relying on a telehealth encounter for certification. Build the check into intake policy: when a referral arrives with a telehealth encounter, confirm the date falls in the window, the modality was permitted on that date, and the note ties the visit to the primary reason for home health.

Face-to-face problems cluster at intake, especially for community referrals where no hospitalist note exists:

• Encounter outside the window: more than 90 days before SOC, or never completed within 30 days after
• Encounter unrelated to the primary reason for home health, such as a routine visit for a different condition
• Missing or inconsistent encounter date on the certification
• Practitioner records that never arrive, leaving the agency unable to support the claim
• Encounter performed by someone not permitted to do it

The fix is workflow: verify the encounter before or at SOC, calendar the 30-day deadline for exceptions, and hold final claims until compliant documentation is on file.