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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 www.cms.gov/Telehealth 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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