CMS has finalized a key update to the Face-to-Face (F2F) encounter policy in the CY 2026 Home Health Final Rule, bringing federal regulations into alignment with the CARES Act and providing added flexibility for home health agencies. Under the updated rule, physicians, nurse practitioners, clinical nurse specialists, and physician assistants may perform the F2F encounter—even if they are not the certifying practitioner and were not involved in the patient’s prior acute or post-acute care.

This change is expected to reduce admission delays, improve care coordination, and ease operational bottlenecks caused by limited practitioner availability. Importantly, CMS preserved the core safeguards tied to certification and documentation.

What Changed
CMS will now allow the following practitioners to perform the F2F encounter:

Physicians

Nurse Practitioners (NPs)

Clinical Nurse Specialists (CNSs)

Physician Assistants (PAs)

Why This Matters

Greater flexibility in meeting F2F requirements

Fewer delays in starting care

Clear alignment with CARES Act authority (effective since 2020)

What Stays the Same

The certifying practitioner must still sign the certification and plan of care

The encounter must occur within 90 days before or 30 days after the start of care

Documentation must continue to clearly support homebound status and skilled need

HCA will continue to monitor CMS guidance as implementation details evolve and will share updates as additional clarification is issued.