After face-to-face encounter documentation caused 480 claim denials under medical review in the last three months of 2023, Medicare Administrative Contractor (MAC) Palmetto GBA is reminding agencies of the requirements and how to avoid these denials.
Face-to-face encounters is the top reason for medical review denials when documentation is submitted for review. It accounted for more than half of denials when requested documents were reviewed between October and December 2023 in Palmetto's 16 states.
On March 29, Palmetto published a reminder for agencies on how 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 documentation of the encounter must describe how the patient’s clinical condition as observed during that encounter supports the patient’s homebound status and need for skilled services
  • 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.