December 12, 2017 | Net Health

3 Minute Read

Complying with CMS’ Face-to-Face Requirements

As mandated by the Affordable Care Act, prior to certifying a patient’s eligibility for the home health benefit, a physician or a permitted non-physician practitioner (NPP) must provide documentation of a face-to-face (F2F) encounter with a patient to demonstrate his/her knowledge of the patient’s condition, and the need for home health skilled services.

Despite being implemented more than five years ago, home health agencies continue to face challenges with compliance—primarily around missing, invalid or incomplete documentation due to the confusing and complex nature of the rule and administrative burden it places on both physicians and home health agencies. However, because F2F documentation is a condition of payment, many home health agencies are denied reimbursement for services delivered.

In fact, according to the Home Care Association (HCA) of New York State, F2F documentation has been “virtually conditioned for provider error while delaying access to patient care and unfairly denying payment to home health providers in stunning sums.”

Stakeholders in the home health industry, including the HCA of New York State, have advocated for the revision of the F2F requirement.

Among its recommendations to Congress, HCA has called for a revision of the requirement so the F2F mandate can be met through a modified version of the existing 485 form, and a provision of financial protection to home health agencies that admit a patient in good faith—with the expectation that a qualified F2F encounter has or will occur on a timely basis with the appropriate documentation—in the event of non-compliance through no fault of their own.

Documentation Requirements

 Under the regulation, physicians and post-acute care providers must provide supporting medical documentation upon request to the home health agency, review entities and/or CMS. If the documentation is considered insufficient, the home health agency won’t receive payment.

However, F2F documentation is not always clear about a patient’s need for home health. As a result, agencies need to be proactive about ensuring compliance. They can do this by supplementing medical records in two ways: they can provide information to the certifying physician that supports the patient’s homebound status and need for skilled care—as long as it substantiates the physician’s entries about the patient’s diagnosis or condition—or they can obtain documentation, such as a discharge summary.

In addition to having a physician sign off on these supplemental materials, the patient’s medical records must contain the actual clinical note for the F2F encounter visit.

For these reasons, home health agencies should obtain the clinical note for the F2F encounter and keep thorough and updated documentation of the patient’s overall health and clinical conditions.

Keeping Track of It All

It’s important that the technology you’re using to document patient care can adequately support efforts to comply with the F2F mandate. At a minimum, EMR software should allow you to:

  • Track physician signatures, patient documentation and clinical notes
  • Alert you when these materials are missing, incomplete or inaccurate


While supporting documents from home health agencies are not required prior to billing, agencies must be able to provide them to CMS and its reviewers upon request, according to the Center for Medicare Advocacy. So, instead of being put in a position where you’re chasing down clinicians, signatures and other documentation after the fact, you can ensure everything is captured in the medical record at the start of care.

 For more information about how Optima’s home health solution can support F2F and other regulatory requirements, watch a demo or schedule a personalized demo for your agency.

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