Face-To-Face Encounter

As of April 1, 2011 the Centers for Medicare and Medicaid Services (CMS) requires a patient/physician face-to-face encounter as a condition for reimbursement of home health care services.

Carter Healthcare offers a face-to-face encounter form that is unique to our company. It has all the requirements that the face-to-face documentation should include to make it easier for you.

Download Carter Face to Face Document

The form requires a few simple things:

  • Patient’s name
  • Date of the face-to-face encounter
  • Specific medical condition that requires home health
  • Services necessary that will be required of Carter Healthcare
  • Justification to support the need for those medically necessary services
  • Justification to support the patient’s homebound status
  • Signature and date of qualified professional that performed face-to-face

Here are some helpful tips to clarify that home health services are medically necessary:

  • Reasonable and necessary for the diagnostics and treatment of an injury or illness
  • Warranted by the patient’s current and documented medical condition
  • Must include intermittent
    • Skilled nursing, or
    • Physical therapy, or
    • Continued occupational therapy

Example: HHC/PT required due to need for skilled nursing and PT/OT services.

The form also requires that the doctor clarify the findings that this patient is considered homebound status:

  • Normal inability to leave home, but if they do so, it requires:
    • A considerable and taxing effort
    • The aide of assistive devices
  • Absences from home are infrequent and are relatively short in duration
  • Medical reasons, religious services, and unique family events are permitted
  • Homebound status does not necessarily mean “bedbound”

Example: Patient is homebound due to SOB with minimal exertion.

Here is a list of the qualified professionals that can perform a face-to-face visit

  • Ideally done by the patient’s primary care physician
  • NPP, PA, CNS, Midwife (but the supervising physician MUST sign off/co-sign)
  • Hospitalist
  • Specialist
  • On-call physician
  • ER physician
  • Physician support staff

Face-to-face encounters must be performed 90 days prior or 30 days following the start of homecare, and must be related to the reason of home health services. It is only required for the initial home health certification period.

The rules are a little different for hospice services but the same Carter Healthcare face-to-face form can still be used.


As a condition for reimbursement of hospice services, the Centers for Medicare and Medicaid Services has implemented a new rule requiring patient/physician face-to-face encounters for hospice patients who are expected to reach the third benefit period (usually on the 180th day).

Who qualifies to perform the face-to-face encounter?

  • A hospice physician, defined as a physician either employed by or working under arrangement with a hospice

  • Residents and fellows who are employed or under agreement with the hospice agency

  • Employed nurse practitioners

When does the face-to-face encounter need to take place?

  • Up to 30 days prior to the beginning of the third or later benefit period (usually begins on the 180th day)

  • The total recertification process (face-to-face encounter, physician narrative and signed certification of terminal illness) must be complete 15 days prior to the beginning of the third or greater benefit period (usually begins on 180th day)