Face-to-Face Encounters are once again a central topic of discussion in Home Health. The regulation has been in place since 2011, with an update issued in 2015. Since April 1, 2015, the regulation itself has remained unchanged. However, over the past decade, including in 2025, there have been numerous clarifications.
A few months ago, issues began to arise with denials related to Face-to-Face Encounters, specifically in cases involving Community Referrals. The denials occurred when the physician who conducted the Face-to-Face Encounter was not the Certifying Physician. This led to widespread concern across the country, as this had not been the practice in previous years.
We’d like to show you an excerpt from a clarification issued by Palmetto GBA on May 8, 2025: “including that a Certifying Physician or Physician with privileges caring for a patient in an acute or post-acute care facility, in which the patient is directly admitted to home health, may conduct and sign the Face-to-Face Encounter.”
Please note—it clearly states, as it always has, “from an acute or post-acute care facility in which the patient is directly admitted to home health.” This means that if the patient is first in a hospital, then moves to a skilled nursing facility (SNF), and the SNF is the one discharging the patient to home health, the Face-to-Face Encounter must come from the SNF.
The Certifying Nurse Practitioner, Certifying Nurse Specialist, Clinical Nurse Specialist, or Nurse Practitioner provision—implemented around 2020, through waivers issued during the public health emergency—allowed these additional providers to certify home health patients and perform the Face-to-Face Encounters.
The clarification being specifically discussed today states: “A community provider can perform the Face-to-Face Encounter, even if they are not the certifying provider. Evidence of collaboration must be included in the documentation, which verifies that prior to the certification, the certifying provider collaborated with the provider who performed the Face-to-Face Encounter.”
The most significant clarification to note is: “No evidence of collaboration is required if it can be determined that the certifying provider and the provider who performed the Face-to-Face are from the same physician practice.” This means that if a physician certifies the home health patient and a nurse practitioner under that same practice performs the Face-to-Face Encounter—or even if another physician within the same practice conducts it—it is considered acceptable. This guidance comes from Palmetto GBA, and can be reviewed by clicking here.
To clarify, the Face-to-Face Encounter must take place either within 90 days before or within 30 days after the Start of Care date. During that encounter, the primary diagnosis related to the Start of Care and the Plan of Care must be treated.
Also remember that telehealth Face-to-Face Encounters remain allowable through September 30, 2025.
In a telehealth setting, it’s important that the Physician or Non-Physician Practitioner conducting the Face-to-Face Encounter clearly documents that the visit included both audio and video components, and that it was conducted using a HIPAA-compliant platform.
Healthcare Provider Solutions is here to support you with any Face-to-Face Encounter needs you may have. Don’t forget—we’ll be covering Medical Review in relation to Face-to-Face Encounters during our upcoming two-day HPS Alliance Home Health Workshop in August, taking place in Nashville, TN. For more information, and to register, click here.
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