Medicare reviewers must now accept home health certifications from nurse practitioners and PAs. Here's what changed Nov. 2

Starting Nov. 2, 2026, CMS's Program Integrity Manual tells Medicare review contractors to accept home health certification documentation from nurse practitioners, clinical nurse specialists and physician assistants. The 2020 CARES Act already let these practitioners certify home health. Transmittal R13972PI updates the auditors' manual to match. Agencies still need all five certification elements documented.

Key facts - What: CMS Transmittal 13972, Change Request 14627, Program Integrity Manual chapter 6 - Dates: issued Sept. 30, 2026; effective Nov. 2, 2026 - Who can certify: physicians and "allowed practitioners" (PAs, NPs and clinical nurse specialists) - Contractors "shall accept" documentation from an NP, CNS or PA (requirement 14627.1) - CMS lists no provider education for this change

What changed on Nov. 2?

CMS rewrote the home health sections of chapter 6 of its Medicare Program Integrity Manual, the rulebook Medicare Administrative Contractors and other review contractors use when they audit claims. Everywhere the old text said "physician," it now says "physician or allowed practitioner." The one business requirement in the change request says contractors shall accept documentation from a nurse practitioner, clinical nurse specialist or physician assistant. CMS issued it Sept. 30, 2026, and it took effect Nov. 2.

Who counts as an allowed practitioner?

A physician assistant, nurse practitioner or clinical nurse specialist, as defined in federal rules at 42 CFR 484.2. Section 3708 of the CARES Act, signed March 27, 2020, let these practitioners order home health, certify that a patient qualifies and set up the plan of care. The transmittal says it brings the review manual in line with that law.

What do reviewers check in a certification?

The updated manual lists five things the certifying physician or allowed practitioner attests to, and reviewers look for supporting records for each:

• Homebound. The patient is confined to the home under Medicare's two-part definition.
• Skilled need. The patient needs intermittent skilled nursing, physical therapy or speech-language pathology services, as defined in 42 CFR 409.42(c).
• Plan of care. A plan was set up and is periodically reviewed by the physician or allowed practitioner, as required by 42 CFR 409.43.
• Under care. Services are furnished while the patient is under the care of a physician or allowed practitioner.
• Face-to-face encounter. It happened no more than 90 days before or 30 days after the start of care, related to the main reason for home health, and its date is documented in the certification.

CMS doesn't require a specific form or format, as long as the certifier attests to all five, the manual says.

Does home health agency paperwork count?

Only if the certifier signs off on it and it becomes part of their record, or the record of the hospital or post-acute facility the patient came from. The manual says agency documentation such as the plan of care or OASIS assessment can support homebound status and skilled need once it's incorporated. It's considered timely if it's signed off before or when the claim is submitted, and it can't contradict the certifier's own records.

What else should agencies know?

• Certification problems carry forward. If the original certification doesn't meet the requirements, later episodes that need recertification won't be covered either, even if the recertification is fine.
• No financial ties. Reviewers only consider certifications, plans of care and face-to-face documentation from practitioners who don't have a financial relationship with the agency.
• Short records mean denials. If the record doesn't show the patient qualified, the contractor denies payment before it's made or sends an overpayment demand afterward.

The transmittal doesn't say whether any contractor had turned down certifications from nurse practitioners or PAs under the old wording, and we haven't seen reports that they did.

Where does this fit with other changes this fall?

It's one of several home health dates in our fourth-quarter deadlines list. For what Medicare covers and who qualifies, see our home health coverage explainer. Agencies in California under Review Choice should also see our demonstration story.

Sources

• CMS, Transmittal 13972 (Change Request 14627), Sept. 30, 2026 (PDF)
• 42 CFR 484.2, Definitions
• 42 CFR 424.22, Requirements for home health services

Photo: DarkoStojanovic / Wikimedia Commons (via Pixabay), CC0 (cropped). A stethoscope and pen on paperwork. File photo from December 2014.

Informational only, not billing, legal or clinical advice. Check the linked primary source and your Medicare Administrative Contractor.

This item has not been clinically reviewed. It is general information, not medical, billing or legal advice.

Drafted with AI assistance from primary sources. Written and edited by the Home Health Brief newsroom under Monsaur Othman's editorial standards. Read how we use AI, our editorial policy and our corrections policy.