Lately, there has been a noticeable increase in denials due to invalid Face-to-Face documentation, affecting several home health agencies and raising concerns across the industry. Many of these denials seem to involve cases that came through Community Referrals.
Let’s review the F2F requirements and applicable guidelines to clarify documentation expectations and ensure compliance moving forward.
Who Can Perform the Face-to-Face Encounter?
Here are some guidance and clarifications referencing Palmetto GBA
1. F2F Must Come from the Discharging Facility
Palmetto GBA has recently issued an important clarification stating:
“A Certifying Physician or a physician with privileges caring for a patient in an acute or post-acute care facility, from which the patient is directly admitted to home health, may conduct and sign the Face-to-Face Encounter.”
This means the F2F Encounter must be completed and signed by a provider from the facility that directly discharges the patient to home health. For instance, if a patient is admitted to a hospital, then transferred to a skilled nursing facility (SNF), and the SNF is the one discharging them to home health, the F2F must come from a provider at the SNF—not the hospital.
2. Non-Physician Practitioners May Perform F2F
Since the public health emergency around 2020 to present, certain non-physician providers have been allowed to conduct F2F Encounters and certify patients for home health. These include:
– Nurse Practitioners (NPs)
– Clinical Nurse Specialists (CNSs)
– Physician Assistants (PAs)
3. F2F by a Non-Certifying Community Provider Is Allowed—with Collaboration
Palmetto further clarified that:
“A community provider may perform the Face-to-Face Encounter, even if they are not the certifying provider. However, documentation must include evidence of collaboration, showing that the certifying provider collaborated with the individual who performed the F2F Encounter prior to certification.” Learn more >
In short, it is acceptable for a non-certifying provider to perform the F2F—as long as collaboration is clearly documented.
4. No Collaboration Needed Within the Same Practice
There is one key exception to the collaboration requirement:
“No evidence of collaboration is required if the certifying provider and the F2F provider belong to the same physician practice.”
So, if a nurse practitioner or another physician within the same practice as the certifying physician conducts the F2F Encounter, no additional documentation of collaboration is needed.
Key Requirements to Remember
- The Face-to-Face Encounter must occur within 90 days before or within 30 days after the Start of Care date.
- The encounter must relate to the primary diagnosis and Plan of Care that initiated home health services.
- Telehealth remains an option for conducting F2F Encounters through September 30, 2025. For telehealth to be valid:
- The visit must include both audio and video components.
- It must be conducted on a HIPAA-compliant platform.
- The provider must clearly document the use of telehealth in the clinical record.
F2F documentation compliance with CMS requirements is critical for proper code assignment and claims affirmation. To support this, intake teams and coders must be well-versed in current F2F guidelines. A solid understanding of these requirements goes a long way in preventing denials and keeping the billing process smooth and efficient.
