CMS Pub. 100-02, ch. 7, § 30.5.1

A certification (versus recertification) is considered to be anytime that a Start of Care

OASIS is completed to initiate care. In such instances, a physician or allowed

practitioner must certify (attest) that:

1. The home health services are or were needed because the patient is or was confined to

the home as defined in §30.1.1;

2. The patient needs or needed skilled nursing services on an intermittent basis (other

than solely venipuncture for the purposes of obtaining a blood sample), or physical

therapy, or speech-language pathology services. Where a patient’s sole skilled service

need is for skilled oversight of unskilled services (management and evaluation of the care

plan as defined in §40.1.2.2), the physician or allowed practitioner must include a brief

narrative describing the clinical justification of this need as part of the certification, or as

a signed addendum to the certification;

3. A plan of care has been established and is periodically reviewed by a physician or

allowed practitioner;

4. The services are or were furnished while the patient is or was under the care of a

physician or allowed practitioner;

5. For episodes/periods with starts of care beginning January 1, 2011 and later, in

accordance with §30.5.1.1 below, a face-to-face encounter occurred no more than 90 days

prior to or within 30 days after the start of the home health care, was related to the

primary reason the patient requires home health services, and was performed by a

physician or non-physician practitioner. The certifying physician or allowed practitioner

must also document the date of the encounter.

Example Certification Statement:

I certify that this patient is confined to his/her home and needs intermittent skilled

nursing care, physical therapy and/or speech therapy or continues to need occupational

therapy. The patient is under my care, and I have authorized services on this plan of

care and will periodically review the plan. The patient had a face-to-face encounter

with a physician or an allowed non-physician practitioner on 11/01/2020 and the

encounter was related to the primary reason for home health care.

Physician or allowed practitioner’s Signature and Date Signed: John Doe, MD

11/05/2020

Physician or Allowed Practitioner’s Name and Address

John Doe, MD

2121 Washington Pkwy

Suite 220

Washington, DC 20000

NOTE: This represents one example of a valid certification statement. Certification

statements can be included in varying forms or formats as long as the content

requirements (#1-5 above) for the certification are met.

If the patient is starting home health directly after discharge from an acute/post-acute care

setting where the physician or allowed practitioner, with privileges, that cared for the

patient in that setting is certifying the patient’s eligibility for the home health benefit, but

will not be following the patient after discharge, then the certifying physician or allowed

practitioner must identify the community physician or allowed practitioner who will be

following the patient after discharge. One of the criteria that must be met for a patient to

be considered eligible for the home health benefit is that the patient must be under the

care of a physician or allowed practitioner (number 4 listed above). Otherwise, the

certification is not valid.

The certification must be complete prior to when an HHA bills Medicare for

reimbursement; however, physicians and allowed practitioners should complete the

certification when the plan of care is established, or as soon as possible thereafter. This is

longstanding CMS policy as referenced in Pub 100-01, Medicare General Information,

Eligibility, and Entitlement Manual, chapter 4, section 30.1. It is not acceptable for

HHAs to wait until the end of a 60-day certification period to obtain a completed

certification/recertification.