Home Health & Hospice Week

Forget the ides of March: Beware missing encounter date.

According to Medicare regs, a physician must certify that the following five requirements are met:

1. The patient needs intermittent SN care, PT, and/or SLP services;
2. The patient is confined to the home (that is, homebound);
3. A plan of care has been established and will be periodically reviewed by a physician;
4. Services will be furnished while the individual was or is under the care of a physician; and
5. A face-to-face encounter:

     a. Occurred no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care;
     b. Was related to the primary reason the patient requires home health services; and
     c. Was performed by a physician or allowed Non-Physician Practitioner.

Item 5a includes that the physician - not the home health agency - document the date of the encounter, MAC CGS says on its website.

The certification must include both the date the encounter occurred and the date the physician signed, the MAC emphasizes. "If the agency's current physician certification statement does not document the date of the face to face encounter, a statement" including the info "can be added to another locator on the plan of care," CGS adds.

CGS offers this example of a valid cert statement at https://cgsmedicare.com/hhh/pubs/news/2018/0118/cope5731.html:

"I certify that this patient is confined to his/her home and needs intermittent skilled nursing care,

physical therapy and/or speech therapy or continues to need occupational therapy. The patient is under my care, and I have authorized services on this plan of care and will periodically review the plan. The patient had a face-to-face encounter with an allowed provider type on 11/01/2016 and the encounter was related to the primary reason for home health care.

Physician's Signature and Date Signed: John Doe, MD 11/05/2016

Physician's Name and Address
John Doe, MD
2121 Washington Pkwy
Suite 220
Washington, DC 20000."

Note: The five cert elements are in MLN Matters article SE1436 at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1436.pdf.