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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 servicesExternal Website.

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