Home Health Agencies (HHAs) have many challenges ahead as they deal with the requirements of the CY 2011 Final Rule for the Home Health Prospective Payment System (PPS) [PDF]. Among other things, this Rule implements the requirement of the health reform legislation that certifying physicians have face-to-face encounters with patients in order to certify the need for home health services. It also revises assessment and documentation requirements for therapy services, and enrollment requirements for HHAs. Carel T. Hedlund of Ober|Kaler looks at some of the changes.