How long before home health starts can the face-to-face encounter happen?

No more than 90 days before the home health start of care date, or within 30 days after it. If the home health order is based on a new condition that was not evident at a visit in the 90 days before care began, Medicare's manual says the patient has to be seen again within 30 days after admission.

What Is a Face-to-Face Encounter?

Face-to-face encounter

Short answer

A face-to-face encounter is the in-person or telehealth visit, with a physician or another practitioner the regulation allows, that Medicare requires behind every home health certification. It has to relate to the main reason for home health and fall within 90 days before or 30 days after the start of care.

Last reviewed October 30, 2026 by the Remitwright billing team. Editorial policy

Also written asface-to-face encountersF2F encounter

The encounter is part of certifying a patient for the Medicare home health benefit. Federal regulation requires that it be related to the primary reason the patient needs home health, that it take place no more than 90 days before the start of care or within 30 days after it, and that the certifying physician or allowed practitioner document its date as part of the certification¹. It can take place through telehealth, within Medicare’s telehealth rules and its list of payable telehealth services.

Who may perform it changed in the CY 2026 home health final rule, issued on November 28, 2025². CMS finalized a change that lets physicians, as well as nurse practitioners, clinical nurse specialists and physician assistants, perform the encounter whether or not they are the certifying practitioner and whether or not they cared for the patient in the acute or post-acute facility the patient came from. The regulation now lists a physician, a nurse practitioner, a clinical nurse specialist, a physician assistant, and a certified nurse-midwife as authorized by state law. The timing window and the link to the primary reason for home health stayed as they were.

The mistake is treating the date on the certification as the evidence. Medicare’s manual expects the certifying practitioner’s records, or the records of the facility the patient came from, to hold the actual clinical note for the encounter, showing that it happened in the window, related to the primary reason for home health and was performed by an allowed provider type. If that documentation does not show eligibility, Medicare does not pay for the home health services. Get the note with the certification rather than after a reviewer asks for it.

Example

Face-to-face encounter in practice

A patient sees her primary care physician on March 2 for a worsening leg ulcer, and home health starts on April 20, inside the 90-day window. The certifying physician records the March 2 date on the certification, and the agency obtains the visit note, which addresses the ulcer, before the first period claim goes out. Hypothetical example.

Face-to-face encounter

Face-to-face encounter in practice

Where face-to-face encounter comes up in the billing work, and how a dedicated biller handles it.

Questions about a face-to-face encounter