Requirements for which providers can conduct the face-to-face encounter have been updated for 2026.
 
CMS finalized the change in the Home Health Prospective Payment System final rule.
 
The new guidance at §424.22(a)(1)(v)(A) notes the face-to-face encounter must be performed by one of the following:
  • A physician
  • A nurse practitioner
  • A clinical nurse specialist
  • A physician assistant
  • A certified nurse-midwife as authorized by State law
CMS expects that this change will provide more options for valid face-to-face encounters. Previously, the regulations had generally left the certifying physician as the only one allowed to conduct the face-to-face encounter for community referrals.
 
In the final rule, CMS noted that all other requirements for the face-to-face encounter remain unchanged.
 
Officials stressed that the documentation should support that:
  • The practitioner completing the face-to-face encounter has firsthand information about the patient’s primary reason for needing home health services.
  • The practitioner is the most appropriate or knowledgeable provider to complete the face-to-face encounter.
An example of an invalid face-to-face encounter would be a practitioner in optometry conducting the face-to-face encounter for a patient with orthopedic reasons for home health services.
 
In guidance ahead of the regulatory change, Medicare Administrative Contractors stressed that there should be evidence of clear coordination between the provider conducting the encounter and the provider certifying the patient. No evidence is necessary when the providers are in the same practice.