5FF2F and 5FFTF: 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 practitioner documenting that he/she had a face-to-face encounter with the patient, including the date of the encounter 
• The face-to-face encounter must be related to the primary reason the patient requires home health services. While the face-to-face encounter must be related to the primary reason for home health services, the patient’s skilled need and homebound status can be substantiated through an examination of all submitted medical record documentation from the certifying physician or allowed practitioner, acute/post-acute care facility and/or HHA. 
• The certifying practitioner may dictate the face-to-face encounter documentation content to one of the practitioner’s support personnel

Resources

• CMS Internet-Only Manual (IOM), 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