support Medicare home health eligibility for that patient/client, the compiled documentation must be reflective of the clinical findings of that face-to-face encounter as observed by that physician caring for the patient/client in the acute or post-acute facility, thus serving as that physician’s communication to the certifying physician. Further, if the certifying physician chooses to use the encounter documentation from the informing physician as his or her documentation of the face-to-face encounter, the certifying physician must sign and date the documentation, demonstrating that the certifying physician received that information from the physician who performed the face-to-face encounter, and that the certifying physician is using that discharge summary or documentation as his or her documentation of the face-to-face encounter. One physician signature, from the certifying physician, suffices if the face-to-face encounter documentation is co-located with the physician’s certification of eligibility. Otherwise, if the face-to-face documentation is attached as an addendum to the certification (a separate document), the face-to-face documentation and certification each require a signature from the certifying physician. d. Palmetto GBA article published on 04/06/2017 titled “‘Connecting the Dots’ for Face-to- Face Documentation” states: i. The inclusion of a F2F encounter document is a requirement. It is also required that recognition be provided by the certifying physician that an alternate physician created the F2F record on a specific date. There are multiple options that satisfy this requirement. The mechanism to “connect the dots” is often likely to be provided by the home health agency. These are possible options: • The plan of care document is a record that is readily available and must include a signature of the certifying physician. There are multiple avenues for including the F2F recognition on the POC (485). • The date of the F2F encounter may be noted on the POC, the statement may include the name of the physician completing the F2F. This option may be the simplest approach if the F2F document is already in-house with the agency since the date of the F2F encounter and physician who prepared it will be known. A copy of the F2F that was prepared by an alternate physician must be forwarded to the certifying physician for their records. • These same elements may appear on an addendum. The POC and its addendum require the signature of the certifying physician and the signature will validate the existence of the F2F encounter document when the date of the F2F is identified as such on the POC. A copy of the F2F that was prepared by an alternate physician must be forwarded to the certifying physician for their records.
