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Face-To-Face (FTF) Encounters for Home Health Certification 

Effective Date: 
Required for start of care home health certifications on/after January 1, 2011.

Who – Performed by:
The certifying physician or qualified non-physician practitioner (NPP) who is not employed by or has a financial relationship with the home health agency. NPP is defined as a nurse practitioner, physician's assistant, certified nurse midwife, or clinical nurse specialist.

When - Timeframe:

• FTF must occur no earlier than 90 days prior to the start of care (SOC) or within 30 days after the SOC.
• If the FTF encounter occurred within 90 days of the SOC but is not related to the primary reason for home health, the NPP or certifying physician must have a FTF encounter within 30 days after the SOC.

Where - Location:

There is no requirement mandating where the FTF encounter takes place. In addition, Medicare eligible telehealth visits are allowed. See for more information on what constitutes telehealth services under Medicare.

What - Documentation Requirements:

• The certifying physician must document the FTF visit took place regardless of who performed the FTF encounter.
• If FTF encounter performed by NPP, must document clinical findings and provide these to the certifying physician.
• Must be a separate and distinct section of, or an addendum to, the certification.
• The documentation must include:
    o The date of the FTF encounter; and
    o Clinical findings to support that the encounter was related to the primary reason for home care, the patient is homebound, and in
       need of Medicare covered home health services.
• Must be clearly titled, dated and signed by certifying physician.
• HHAs may not formulate standard language on the certification forms related to the encounter.

Additional Information:

• FTF must be related to the primary reason for the home health admission.
• HHAs held responsible for producing the physician's certification documentation when requested.

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