b. Those to Perform the Face-to-Face Encounter: i. Medicare-enrolled physicians who are also the certifying physician. ii. The following physicians are allowed to perform the face-to-face encounter and inform the certifying physician: • Physicians (Medicare-enrolled or otherwise) who cared for the patient/client in an acute or post-acute facility during a recent acute or post-acute stay and have privileges at the facility. • Because physicians in their residencies (Medicare-enrolled or otherwise) do not have privileges at acute or post-acute facilities, if they are performing the encounter and informing the certifying physician, they must inform the certifying physician under the supervision of their teaching physician who must have such privileges. • NPPs allowed to perform the face-to-face encounter include: o A nurse practitioner or clinical nurse specialist working in collaboration with the certifying physician in accordance with state law. o A certified nurse midwife under the supervision of the certifying physician, as authorized by state law. o A physician assistant under the supervision of the certifying physician. • NPPs are subject to the same financial restrictions with the home health agency as the certifying physician. c. Face-to-Face Documentation Requirements: i. Documentation must be clearly titled, dated, and signed by the certifying physician, whether as part of the certification form itself, or as an addendum. It must also include the date the face-to-face encounter was performed. ii. The face-to-face documentation must be that of the certifying physician and cannot be altered or changed in any way by the home health agency. iii. The face-to-face documentation is part of the certification, and the certification is required at the time the home health agency bills Medicare. iv. The face-to-face documentation can include, or exist as, check boxes so long as it comes from the certifying physician. v. If the physician who cared for the patient/client in the acute or post-acute facility chooses to use documentation that is compiled from the patient’s/client’s medical record (e.g., a discharge summary) to inform the certifying physician of how the clinical findings of the face-to-face encounter
