E/M Documentation in the EMR

A surgical oncologist that I work with reviews documentation from referring physicians regarding patients he may need to perform surgery on. This review is prior to the office visit to determine and discuss the treatment plan. He is wanting to start his note with the test results and findings prior to the actual visit. I am telling him this is not compliant or acceptable and he is not understanding why. I know I have read this somewhere and cannot for the life of me find where it is ... if anyone can assist with a credible source stating the note cannot be started prior to the encounter (face-to-face) with the patient, it would be greatly appreciated.

Thank you.