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Home health agencies have been on a rollercoaster ride of confusion regarding the Face-to-Face (F2F) encounter requirements, with the past year being especially frustrating. Since implementation of the F2F encounter requirement in 2011, the regulation has been interpreted, updated, and/or changed several times. Within the past year, interpretations by the Medicare Administrator Contractors (MACs), pandemic waiver extensions for telehealth, and two government shutdowns have caused agencies to interrupt admission processes and struggle with providers in explaining what is currently required. It has been a challenge to say the least.

Thankfully, the most recent home health final rule for 2026 simplifies the requirements of the F2F encounter and Congress has passed the latest resolutions which include extension of the telehealth flexibilities though December 31, 2027. With these, home health agencies should feel some stability with their F2F processes. The following F2F requirements are currently in effect:

• With the CY 2026 Home Health Final Rule, the Centers for Medicare & Medicaid Services (CMS) finalized regulations to allow physicians, Nurse Practitioners (NPs), Certified Nurse Specialists (CNSs), and Physicians Assistants (PAs) to perform the F2F regardless of whether they are the certifying practitioner or whether they cared for the patient in the acute or post-acute facility from which the patient was directly admitted to home health and who is different from the certifying practitioner. This means that any qualifying community practitioner can perform the F2F encounter for another community practitioner certifying the patient for home health. 

• The Consolidated Appropriations Act of 2026 passed by Congress and signed by the President 2/3/2026 contains provisions that extend the telehealth flexibilities from the pandemic. This means for home health providers, it removes the geographical requirement and expands originating sites allowing a F2F encounter to be performed in a patient’s home. (Originally, telehealth F2F encounters are only allowed in an approved originating site detailed in Chapter 7 of the Medicare Policy Handbook.) Two-way audio and video is required for telehealth F2F encounters and must be documented accordingly. This extension will expire on December 31, 2027. 

This is good news for home health agencies and especially for patients. With the F2F encounter flexibilities regarding who can provide the encounter and also with telehealth options, patients will now have quicker access to the care they need from home health agencies.