Agencies are getting a little more insight into how the Medicare Administrative Contractors will be enforcing changes to face-to-face encounter requirements.
The 2026 Home Health Prospective Payment System proposed rule included new rules around community referrals, opening up the opportunity for the provider conducting the face-to-face encounter to be different from the provider certifying the patient for home health services.
The MACs released updated guidance in May regarding what they expect to see in the record. Palmetto GBA answered some provider questions submitted during a call June 16.
Response: We would need to ensure that the collaboration between the certifying provider and the face-to-face conductor was completed prior to the date on the certification. We can look for anything that shows that providers are in the same practice, such as letterhead, website or internet listings, etc.
Question: Can you confirm whether any physician may have performed the encounter, as long as it was related to the care for the home health referral? This is an important point, and I want to ensure we fully understand the requirements. Additionally, can you provide guidance on what documentation should be included in the notes from the non-certifying provider? Knowing the specifics will help us maintain compliance and streamline our processes. Lastly, it would be extremely helpful if Palmetto GBA could provide some examples of "evidence of collaboration." Having concrete examples will aid us in accurately documenting and demonstrating collaboration in our records.
Response: You can use any communication between the certifying provider and the face-to-face provider. Are there any calls with the agency and the two providers? Are there any notes sent between the two in the medical record? Because there are no required forms or documents, you would need to determine what documentation you have that shows this collaboration.
Question: Can Palmetto GBA provide updates on physician handoffs being non-affirmed. During our October 2024 meeting, it was shared that some type of documentation would be expected. Can you confirm that the expectation is to show documentation that the communication occurred, not a specific “hand off” or “sign off” type of approval being required?
Response: If the agency has had communications with both providers, please include that documentation of the communication. There is no form or format that is required. We need to see some evidence of the communication that the handoff occurred between the two certifying providers.
HHL subscriber resources: