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Last Modified: 5/8/2018 Location: FL, PR, USVI Business: Part A, Part B

Signature requirements -- guidelines for authentication of Medicare services

The Centers for Medicare & Medicaid Services (CMS) requires that any Medicare service provided or ordered must be authenticated by the author -- the one who provided or ordered that service. Authentication may be accomplished through the provision of a hand-written or an electronic signature; however, stamp signatures are unacceptable, with one exception (physical disability).
In addition, any documentation submitted to substantiate the medical necessity for a service billed to Medicare must clearly identify the patient, date of service, and the provider of the service. The purpose of the authentication (signature) requirement is to ensure that the services rendered have been accurately and appropriately documented, reviewed, and authenticated.

Summary of signature guidelines -- acceptable forms of authentication

The following methods of authentication have been deemed acceptable by CMS:
• Handwritten signature -- a mark or a sign placed on a medical document to signify knowledge, approval, acceptance, or obligation by the individual who provided or ordered the services specified in the medical entry. Requirements for this form of authentication are dependent upon whether the signature is considered legible or illegible.
• Legible signature -- acceptable forms of presentation:
• Legible full signature
• Legible first initial and last name
• Initials placed above a typed or printed name
• Initials accompanied by a signature log -- lists the typed or printed name of the author associated with initials or an illegible signature. Signature logs may be included on the page where the initials or illegible signature is used, or it may be submitted as a separate document.
• Initials accompanied by an attestation statement -- must be signed and dated by the author of the medical record entry, must be associated with a specific medical entry, and must contain sufficient information to identify the beneficiary.
Note: An unsigned handwritten note may be accepted as authentication when other entries on the same page are in the same handwriting and have been signed.
• Illegible signature -- acceptable forms of presentation:
• Illegible signature placed above a typed or printed name
• Illegible signature where the letterhead, addressograph, or other information on the page indicates the identity of the individual who signed the entry. For example, the provider’s name could be circled to indicate the identity of the individual who signed the entry.
• Illegible signature accompanied by a signature log -- lists the typed or printed name of the author associated with initials or an illegible signature. Signature logs may be included on the page where the initials or illegible signature is used, or it may be submitted as a separate document.
• Illegible signature accompanied by an attestation statement -- must be signed and dated by the author of the medical record entry, must be associated with a specific medical entry, and must contain sufficient information to identify the beneficiary.
• Electronic signatures -- an electronic sound, symbol, or process attached to or logically associated with an electronic medical record to signify knowledge, approval, acceptance, or obligation by the individual who provided or ordered the services specified in the medical entry.
• Electronic signatures must be authenticated, safeguarded against misuse and modification, and should be easily identifiable as electronic, rather than typewritten, signatures.
• As the individual represented by the electronic signature bears responsibility for the authenticity of the information, physicians are strongly encouraged to check with their attorneys and malpractice insurers regarding the use of alternative signature methods.

Summary of signature guidelines -- unacceptable forms of authentication

The following methods of authentication have been deemed unacceptable by CMS and may result in a Comprehensive Error Rate Testing (CERT) finding:
• Unsigned, typed note with provider’s typed name.
• Unsigned, typed note without provider’s typed name
• Unsigned, handwritten note (only entry on the page)
• Illegible signature that is not placed above a typed or printed name
• Illegible signature that is not identified in a letterhead or addressograph
• Illegible signature that is not accompanied by a signature log or attestation statement
• Stamp signature
• “Signature on file”

Summary of signature guidelines -- 20-day timeframe for documentation requests

If a claim reviewer requests an attestation statement or a signature log to authenticate a medical record, the organization that billed the claim must submit the documentation to the requestor within 20 calendar days.
The 20-day timeframe begins when:
• The reviewer makes actual phone contact with the provider, or
• The reviewer’s request letter is received by the U.S. Postal Service
Click here for more information regarding the 20-day timeframe.

Signature requirements -- exceptions

• Certification of terminal illness for hospice -- a facsimile of an original written or electronic signature is an acceptable form of authentication for certification of terminal illness for hospice.
• Orders for clinical diagnostic tests -- an unsigned order for a clinical diagnostic test that is accompanied by signed medical documentation that demonstrates the treating physician’s intent for the test to be performed is an acceptable form of authentication for the test.
• Other regulations and CMS instructions -- regarding signature requirements, such as timeliness standards for particular benefits, take precedence over the guidelines listed above. In cases where the relevant regulation, coverage determination, or CMS manual outlines specific signature requirements (e.g., signatures on plans of care must be signed before those services are rendered), those signature requirements will take precedence.
• Physical disability – CMS permits the use of a rubber stamp for signature in accordance with the Rehabilitation Act of 1973 in the case of an author with a physical disability that can provide proof of his/her inability to sign their signature due to their disability. By affixing the rubber stamp, the provider is certifying that they have reviewed the document.

e-Prescribing (eRx) signature requirements

Electronic prescribing is the transmission of prescription or prescription-related information through electronic media. Health care professionals can electronically transmit new prescriptions as well as responses to renewal requests directly to a pharmacy through a qualified eRx system, which eliminates the necessity for writing or faxing prescriptions for non-controlled substances.
Note: CMS defines a “qualified eRx system” as one that meets the Medicare Part D requirements described in Standards for Electronic Prescribing (42 CFR 423.160 external pdf file).
• e-Prescribing for Part B drugs: Non-controlled substances -- if a provider submits an order for a non-controlled substance through a qualified eRx system, the provider is not required to produce a signed hardcopy as evidence to substantiate the drug order.
• e-Prescribing for Part B drugs: Controlled substances -- the Drug Enforcement Agency (DEA) does not permit the prescribing of controlled substances through e-Prescribing systems; therefore, only a signed (pen and ink) hardcopy of the prescription will be accepted as evidence to substantiate a drug order for controlled substances.
Note: CMS outlines signature requirements for medical documentation as well as exceptions to the guidelines in the Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4 external pdf file.
Source: CR 6698
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