We have received a number of questions from agencies regarding the Face-to-Face (F2F) encounter requirements following the CY 2026 Home Health Final Rule, effective January 1, 2026. The most important clarification is the following:

The practitioner completing the F2F encounter does not need to be the certifying provider and does not need to have previously treated the patient in the acute or post-acute setting from which the patient is transitioning to home health. This flexibility also applies to referrals originating from the community, meaning the certifying physician does not need to be the practitioner who performed the F2F encounter.

 This clarification is intended to reduce delays during care transitions and reflects CMS’s effort to better align the regulation with real-world referral workflows. Agencies may continue to rely on appropriate, recent clinical documentation that clearly supports the reason for home health services and falls within required timeframes.

All other F2F requirements remain unchanged, including the certifying provider’s responsibility to review, sign, and date the certification and confirm homebound status and skilled need.