Allowable Face-to-Face Requirement Scenarios

What happens when the allowed practitioner attests to a face-to-face encounter on a different date than that of the encounter note?

Answer: If there is an encounter note signed by the provider who performed the encounter that meets requirements, even though it does not match the date attested to, this would be accepted as meeting the face-to-face element of the certification as long as the encounter was within the timeline and related to the primary reason for home health.

What if the certifying provider did not document the date of the face-to-face, but the encounter note provides the relevant information?

Answer: If there is no statement attesting or certifying that a face-to-face encounter occurred, but there is a face-to-face visit note in the medical record that meets the requirements, and this face-to-face was completed by and is signed by the certifying practitioner, or it has been incorporated into the certifying provider’s medical record by signing and dating the note as well as having been signed by the provider who performed the face-to-face (if not the certifying physician), then this would be accepted as meeting the face-to-face element of the certification as long as the encounter was within the timeline and related to the primary reason for home health.