Health Information Management

Healthcare News: CMS updates guidance on signature requirements

JustCoding News: Inpatient, March 31, 2010

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On March 16, CMS issued Transmittal 327 in the Medicare Program Integrity Manual, which provides additional detail regarding signature requirements.

As part of the revised language, CMS states, “For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a hand written or an electronic signature. Stamp signatures are not acceptable.”

In addition to the previously noted exception to this guidance (i.e., facsimile of original written or electronic signatures are acceptable for the certifications of terminal illness for hospice), CMS added two more exceptions:

  • Orders for clinical diagnostic tests are not required to be signed. However, the treating physician must authenticate via a handwritten or electronic signature their documentation that he or she intended to perform the clinical diagnostic test.
  • Other regulations and CMS instructions regarding signatures (such as timeliness standards for particular benefits) take precedence. For cases where the relevant regulation, NCD, LCD and CMS manuals have specific signature requirements, those signature requirements take precedence.

When the reason for a pre- or post-payment denial is unrelated to the signature requirement, CMS states that the contracted reviewer can disregard the signature authentication process. However, CMS instructs the reviewer to proceed to the signature assessment procedure when the reviewer cannot meet the criteria in the specific Medicare policy because the documentation is missing a signature or it is illegible.

To learn more about CMS guidance about illegible signatures and missing signatures, access Transmittal 327.

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