Provider Notice issued 12/11/13

Face to Face Encounter Requirements for Home Health Care Services

To:​ Enrolled Home Health Agencies, Physicians, Advanced Practice Nurses, and Health Departments ​
Date:​ December 11, 2013​
Re:​ Face to Face Encounter Requirements for Home Health Care Services

As a result of Public Act 097-0689(pdf), referred to as the Save Medicaid Access and Resources Together (SMART) Act, effective with dates of service, January 1, 2014, and after, the department will require that the initial certification of Home Health intermittent skilled nursing services and/or therapy services  include documentation that a face-to-face encounter was conducted by the practitioner ordering services. 

The following conditions must be met for the face-to-face encounter:

  • The certifying physician must document that the face-to-face encounter is related to the primary reason the patient requires home health services. The encounter must occur no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care. The certification must include the date of the encounter, and an explanation of clinical findings that support the patient’s need of either intermittent skilled nursing services or therapy services. 

  • The face-to-face encounter must be performed by the certifying physician; a nurse practitioner or a clinical nurse specialist who is working in collaboration with the physician in accordance with State law; a certified nurse midwife as authorized by State law; a physician assistant under the supervision of a physician; or for patients admitted to home health immediately after an acute or post-acute stay, the physician who cared for the patient in an acute or post-acute facility and who has privileges at the facility.  The documentation of the face-to-face encounter must be a separate and distinct section of, or an addendum to, the certification and must be clearly titled, dated, and signed by the certifying physician.

  • If the certifying physician does not perform the face-to-face encounter personally, the non physician practitioner or the physician who cared for the patient in an acute or post-acute facility who performed the face-to-face encounter must communicate the clinical findings of the face-to-face encounter to the certifying physician. The certifying physician has the discretion on what type of communication they will accept from the practitioner who completed the actual face-to-face encounter. The certification must be clearly titled, dated, and signed by the certifying physician.

  • If a face to face patient encounter occurred within 90 days prior to the start of care but is not related to the primary reason the patient requires home health services, or the patient has not seen the certifying physician or allowed non physician practitioner within the 90 days prior to the start of the home health episode, the certifying physician or non physician practitioner must have a face-to-face encounter with the patient within 30 days after the start of the home health care.

  • The face to face encounter may occur through telehealth.

  • The face to face certification is not considered a separate allowable service and will not be separately reimbursed to practitioners if billed.

Providers must submit documentation of the face-to-face encounter with the Plan of Care for services that require prior approval.  Providers must maintain documentation of the face-to-face encounter in the participant’s record regardless if the service requires prior approval.

The face-to-face encounter requirement does not apply to re-certifications or services provided by a home health aide.

Any questions regarding this notice may be directed to the Bureau of Professional and Ancillary Services, formerly Bureau of Comprehensive Health Services, at 1-877-782-5565.  Please use option 3 and then option 5 for billing questions or option 5 and then 2 for prior approval questions. 

Theresa A. Eagleson, Administrator

Division of Medical Programs