Part 2: Face to Face Encounters

Good Afternoon MFS Bloggers, Here is Part 2 of CMS Clarification Guidelines on the Face to Face Encounters.

Is the same physician required to sign both the plan of care (POC) and certification of the need for home health care?

Per CMS, Prior to calendar year (CY) 2011, the Centers for Medicare & Medicaid Services (CMS) manual guidance required the same physician to sign the certification and the plan of care (POC). Beginning in CY 2011, CMS will allow additional flexibility associated with the POC when a patient is admitted to home health from an acute or post-acute setting. For such patients, physicians who attend to the patient in acute and post-acute settings are authorized to certify the need for home health care based on their face-to-face contacts with the patient (which includes documentation of the face-to-face encounter), initiate the orders (POC) for home health services and ‘hand off’ the patient to his or her community-based physician to review and sign off on the POC. CMS continues to expect that in most cases, the same physician will certify, establish and sign the POC, but the flexibility exists for home health post-acute patients if needed.

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