Palmetto GBA is introducing new guidance on who can perform the face-to-face encounter for community admissions.
 
Published May 8, the guidance states that a community provider can perform the face-to-face encounter, even if they are not the certifying provider.  
 
In the past, providers have struggled with denials based on a strict interpretation of the rules that the certifying practitioner must be the same provider who had the face-to-face encounter unless the patient is coming to home health directly from an acute or post-acute facility.  
 
In this new guidance, Palmetto states that different community providers can certify and conduct the face-to-face encounter.
The guidance includes two notes:
  • Evidence of collaboration must be included in the documentation verifying 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.
See the Palmetto guidance at palmettogba.com.
 
Look for more information on this update and analysis from experts on how to approach changes to your practices in an upcoming issue of Home Health Line.