This resource is part of the AMA's Debunking Regulatory Myths series, supporting AMA's practice transformation efforts to provide physicians and their care teams with resources to reduce guesswork and administrative burdens.
Debunking the myth
There is no CMS requirement specifying that physicians or allowed non-physician practitioners must sign every single page of home health agency (HHA) plan of care (POC) certifications or recertifications. The format of the document and the way in which timely certification or recertification is obtained is left to the determination of the individual home health agency.1,2
Additionally, if the physician or allowed non-physician practitioner (NPP) who established the POC and signed the certification is unavailable (e.g., due to vacation, illness, or extended leave), another authorized clinician may sign the HHA recertification.3 The HHA is responsible for ensuring that the signing clinician was authorized by the clinician who originally established the POC and signed the certification.1,3
Background
When certifying and recertifying home health POCs, physicians and allowed NPPs (nurse practitioners, clinical nurse specialists, and physician assistants) are often met with conflicting instructions regarding how they should sign the document. Signing and dating every page of a home health certification can unnecessarily add administrative work and consume time.
Further, home health organizations often require certifying clinicians to re-sign recertifications, even when an authorized clinician signed on their behalf during a vacation, family or medical leave, or extended time away. This unnecessary re-signing creates unnecessary extra work upon their return.
Takeaway
Eliminating unnecessary organizational policies that require physicians to sign every page of HHA POC certifications and recertifications—or that prevent other authorized clinicians from signing recertifications in the certifying physician’s absence—can reduce administrative burden, duplicative work, and burnout. Such changes support physicians in fully disconnecting during time off and allow them to focus more of their time on patient care.
Resources
- 2023 Revisions to Medicare General Information, Eligibility, and Entitlement: Physician Certification and Recertification of Services (PDF). Accessed July 2022.
- 2022 MLN Fact Sheet (PDF): Complying with Medicare Signature Requirements. Accessed July 2022.
- 2023 Revisions to Medicare Benefit Policy Manual: Home Health Services. Accessed July 2025.
- Download this myth: How should physicians sign home care plan of care recertifications? (PDF)
References
- Centers for Medicare & Medicaid Services. Medicare General Information, Eligibility, and Entitlement Chapter 4- Physician Certification and Recertification of Services. Vol Rev. 12425.; 2023. Accessed July 9, 2025. https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/ge101c04.pdf
- Centers for Medicare & Medicaid Services. Complying with Medicare Signature Requirements. MLN Fact Sheet; 2024. Accessed July 9, 2025. https://www.cms.gov/files/document/mln905364-complying-medicare-signature-requirements.pdf
- Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual Chapter 7- Home Health Services. Vol Rev. 12425.; 2023. Accessed July 9, 2025. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c07.pdf
Earn CME
Debunking Regulatory Myths overview
Visit the overview page for information on additional myths.
Disclaimer: The AMA's Debunking Regulatory Myths (DRM) series is intended to convey general information only, based on guidance issued by applicable regulatory agencies, and not to provide legal advice or opinions. The contents within DRM should not be construed as, and should not be relied upon for, legal advice in any particular circumstance or fact situation. An attorney should be contacted for advice on specific legal issues. Additionally, all applicable laws and accreditation standards should be considered when applying information to your own practice.
