Home Health & Hospice

CMS Clarifies Use of Rubber Stamp Signatures

Homecare Insider, June 3, 2013

The Centers for Medicare and Medicaid Services (CMS) has issued Change Request (CR) 8219, which clarifies the use of a rubber stamp for signature.

According to the CR, for medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a handwritten or electronic signature. Stamped signatures are not acceptable.

CMS does offer several exceptions to this mandate. The first three exceptions are nothing new, but the fourth exception is newly featured in this change request. This exception gives flexibility to an author with a physical disability.

  1. Facsimiles of original written or electronic signatures are acceptable for the certifications of terminal illness for hospice.
  2. There are some circumstances for which an order does not need to be signed. For example, orders for some clinical diagnostic tests are not required to be signed. The rules in 42 CFR 410 and Pub.100-02 chapter 15, §80.6.1 state that if the order for the clinical diagnostic test is unsigned, there must be medical documentation (e.g., a progress note) by the treating physician that he/she intended the clinical diagnostic test be performed. This documentation showing the intent that the test be performed must be authenticated by the author via a handwritten or electronic signature.
  3. Other regulations and the CMS’ instructions regarding conditions of payment related to signatures (such as timeliness standards for particular benefits) take precedence. For medical review purposes, if the relevant regulation, NCD, LCD, and CMS manuals are silent on whether the signature needs to be legible or present and the signature is illegible/missing, the reviewer shall follow the guidelines listed below to discern the identity and credentials (e.g., MD, RN, etc.) of the signator. In cases where the relevant regulation, NCD, LCD, and CMS manuals have specific signature requirements, those signature requirements take precedence.
  4. CMS would permit 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 to a CMS contractor 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.
Read the full CR today!

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