Reminders for Authentication of Face-to-Face Encounter Notes and Home Health Certification

It is important to remember that all Medicare requirements must be met for claim payment.

As a condition for payment, the Affordable Care Act mandates that prior to certifying a patient’s eligibility for the home health benefit, the certifying physician must document that he or she, or a qualified nonphysician practitioner (NPP), has had a face-to-face encounter with the patient. For initial home health certifications, the certifying physician must document that the physician, a qualified nonphysician practitioner (NPP), or a physician caring for the patient in an acute or post-acute facility, who has privileges at the facility, had a face-to-face encounter with the patient. 

The rendering practitioner for the face-to-face encounter, author of the encounter note, must sign his or her own note. Another practitioner regardless of affiliation or relationship, cannot sign an encounter note for the original author.

The practitioner listed on the plan of care is the certifying provider for the Home Health period. The certifying provider must sign the plan of care. The certifying practitioner for the Start of Care must attest to the face-to-face encounter and sign his or her name. No other practitioner can sign for the certifying practitioner regardless of affiliation or relationship.

Resources

• Medicare Program Integrity Manual
• Signature Requirements - MLN Matters Article 6698 (PDF)
• Medical Records Signature Attestation Statement 
• Face-to-Face Web Page