5FF2F: Face-to-Face Encounter Requirements Not Met

The services billed were not covered because the documentation submitted for review did not include (adequate) documentation of a face-to-face encounter.

To Prevent This Denial
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.

Specific documentation related to face-to-face encounter requirements must be submitted for review. This includes, but is not limited to:

• 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 brief narrative, 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 certifying physician must document the encounter either on the certification, which the physician signs and dates, or on a signed addendum to the certification
• The certifying physician may dictate the face-to-face encounter documentation content to one of the physician’s support personnel to type. The documentation may also be generated from a physician’s electronic health record.

Resources

• CMS Internet-Only Manuals (IOMs), Publication 100-02, Medicare Benefit Policy Manual Chapter 7, Section 30.5.1.1 (PDF)
• Incorporating Home Health Agency Documentation into the Physicians Medical Record: Supporting Eligibility with Home Health Agency Clinician Notes