Two MACs have now updated their guidance for agencies on who can perform the face-to-face encounter when the patient referral is coming from a community provider.
 
In a message to agencies June 5, CGS shared the same guidance that Palmetto offered its agencies last month.
 
What’s new: A community provider can perform the face-to-face encounter, even if they aren’t the certifying provider. This has been a particular challenge for agencies under medical review in recent years.
 
Experts have warned agencies to wait for clarity from CMS before relying on this new guidance. Regulations have not been updated yet, and this appears to be new guidance in advance of some change in the rules around face-to-face encounters and certifications.
 
Like Palmetto, CGS notes that “documentation must contain evidence that the certifying provider collaborated with the provider who performed the face-to-face encounter prior to the certification.”
 
The example that Palmetto offered on a recent call with agencies was a referral from a primary care physician to a specialist.
If it's clear that the certifying provider and the provider who performed the face-to-face encounter are from the same practice, no evidence of collaboration is required, the messaging notes.