Who Can Perform a Face-to-Face Encounter?

Who can perform the Face-to-Face (F2F) encounter for home health? This seems like a question that would be easy to answer but has proven to be otherwise.

The optimal situation would be when the provider that certifies the patient for home health care would also be the provider that performs the F2F encounter, but we all know that is not always the case. There are situations of an institutional referral, where the patient is admitted to home health from an acute or post-acute setting and a provider from that setting performed the F2F. In that situation, the certifying provider must acknowledge the date of that encounter. In recent months there have been denials when a community referral has someone other than the certifying provider performing the F2F encounter. On May 8, 2025, Palmetto GBA published a clarification regarding community referral that states, in part:

• If a beneficiary was admitted from home and the certifying provider and the face-to-face performing provider are different:
  • A community provider can perform the face-to-face 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
  • 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 practice

Click here for more information: Jurisdiction M HHH – Who Can Perform a Face-to-Face Encounter