Physician Certification

A complete certification attests that:

• The patient is confined to the home (homebound)
• The patient needs intermittent skilled nursing care, physical therapy, or speech-language pathology services
• The patient is under the care of a physician or allowed practitioner
• Services are furnished under a plan of care established and periodically reviewed by that practitioner
• A face-to-face encounter related to the primary reason for home health occurred within 90 days before or 30 days after the start of care, with the encounter date documented

All five must be present. A missing element, most often the face-to-face documentation, makes the certification incomplete and the claim deniable in full.

Certification historically belonged to physicians alone. The CARES Act of 2020 permanently added allowed practitioners: nurse practitioners and clinical nurse specialists working in accordance with state law, and physician assistants practicing under state law requirements. The certifying practitioner must not have a prohibited financial relationship with the agency under the physician self-referral rules, and must be enrolled in Medicare. In practice the certifier is usually the practitioner who will sign the plan of care and orders throughout the episode, which keeps certification, orders, and oversight aligned under one clinician.

The certification should be obtained when the plan of care is established, or as soon as possible afterward, and it must be signed and dated by the certifying practitioner before the agency submits the final claim. There is no payment for episodes with missing or incomplete certifications, and the certification cannot be retroactively fabricated; late signatures are permissible, but the underlying eligibility must have existed at the start of care. Most agencies fold the certification language into the plan of care document so one signature executes both, which is acceptable as long as all required content, including the face-to-face encounter date, is present.

Certification is a favorite target of medical review because a single defect voids the whole claim. Recurring failure modes include face-to-face encounters that are missing, out of window, or unrelated to the primary reason for home health; certifications signed after the final claim went out; missing dates next to signatures; and practitioner records that do not support homebound status or skilled need. Defenses are operational: verify the certifying practitioner's Medicare enrollment at intake, assemble the certification package before billing, date-stamp signature workflows, and hold final claims on episodes where any element is unresolved. Treat the certification as a billing gate, not a formality.