June 5, 2025
Home Health: Who Can Perform a Face-to-Face Encounter?
The face-to-face encounter must be performed by one of the following:
- The certifying physician or a physician with admitting privileges who provided care to the patient in an acute or post-acute care facility prior to the patient's direct admission to home health services.
- The certifying nurse practitioner or clinical nurse specialist, or a nurse practitioner or clinical nurse specialist practicing in accordance with state law, and in collaboration with a physician or acute or post-acute care physician with privileges, who treated the patient in the facility from which the patient was directly admitted to home health services.
If a beneficiary was admitted from home and the certifying and face-to-face performing providers are different:
- A community provider can perform the face-to-face even if they aren't the certifying provider.
- Documentation must contain evidence that the certifying provider collaborated with the provider who performed the face-to-face prior to the certification.
- If it can be determined that the certifying provider and the provider who performed the face-to face are from the same practice, no evidence of collaboration is required.
Reference: Code of Federal Regulations, Section 424.22 Requirements for home health services.