CMS Offers Provider Community Clarity on Face-to-Face Rules

Good Morning MFS Bloggers, In continuing with CMS’s clarification of the face-to-face rules, please be advised of the following issues clarified below:

What happens if the face-to-face encounter is completed during the 90-day period prior to the start of care (SOC) and then the patient’s condition changes?

In situations when a physician orders home health care for the patient based on a new condition that was not evident during a visit within the 90 days prior to start of care (SOC), the certifying physician or an allowed non-physician practitioner (NPP) must see the patient again within 30 days after admission. Specifically, if a patient saw the certifying physician or NPP within the 90 days prior to SOC, another encounter would be needed if the patient’s condition had changed to the extent that standards of practice would indicate that the physician or a non-physician practitioner should examine the patient in order to establish an effective treatment plan.

What role is a hospital permitted to play in certifying the need for home health care?


For Medicare purposes, a physician who attended to the patient but does not follow the patient in the community, such as a hospitalist, is permitted to certify the need for home health care based on that physician’s face-to-face contact with the patient in the hospital. Further, this physician may establish and sign the plan of care (POC), initiate the orders for home health services and ‘hand off’ the patient to his or her community-based physician to review and sign off on the POC. Only the certifying physician or certain non-physician practitioners (NPPs) can perform the face-to -face encounter. Additionally, only Medicare-enrolled physicians can certify home health eligibility, per the Affordable Care Act.

Leave a Reply