CMS Posts Face-to-Face Clarification Guidelines

Can the face-to-face documentation be included with the Plan of Care (POC) and certification documentation?

Answer:

Per CMS, The Affordable Care Act requires the face-to-face encounter and corresponding documentation as a certification requirement. In other words, the face-to-face encounter is an additional certification requirement. Long-standing regulations have described the distinct content requirements for the plan of care (POC) and certification. Providers have the flexibility to implement the content requirements for both the POC and certification in a manner that works best for them. Many providers have implemented the requirements for the POC and certification by using one form which meets all the content requirements of both the POC and certification. This approach is acceptable and it will continue to be acceptable.

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