Pre-Claim Review Non-Affirmations: Face-to-Face Encounter

Below are the top reasons for non-affirmations due to the Face-to-Face Encounter:

  • The physician certification was invalid since the required face-to-face encounter document was missing
  • The physician certification was invalid since the required face-to-face encounter was untimely and/or the certifying physician did not document the date of the encounter
  • The physician certification was invalid since the required face-to-face encounter was not related to the primary reason for home health services

The certifying physician must document that he/she or an allowed nonphysician practitioner (NPP) had a face-to-face encounter with the patient, including the date of the encounter. The documentation of the encounter must include a note, composed by the certifying physician, describing how the patient’s clinical condition as observed during that encounter supports the patient’s homebound status and need for skilled services. The face-to-face encounter must occur no more than 90 days prior to the home health start of care date or within 30 days after the start of care. The certifying physician must document the encounter either on the certification, which the physician signs and dates, or on a signed addendum to the certification.

Example of Inadequate Face-to-Face Encounter Note

The face-to-face encounter documentation for encounter date 05/28/20XX "Diabetes Mellitus, Hypertension, BP elevated." Homebound status was documented as “Schizophrenia – confused periods.”

  • There is no explanation of how the beneficiary was homebound
  • There is no explanation of the need for skilled services

For more information see CMS Internet-Only Manuals (IOMs), Publication 100-02, Medicare Benefit Policy Manual Chapter 7, Section 30.5.1.1 (PDF, 455.39 KB).

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