Physician signature clarification....

Physician Signature on documentation has become a real "hot button" issue lately. It was brought to my attention from one of my co-workers. We have had to make some changes in our billing and coding practice to accomodate this directive. According to Cigna Government services August bulletin, it contained the following information:

http://www.cignagovernmentservices.com/partb/pubs/mb/2009/08_09/PDFs/TN_2009_08.pdf

The CERT review process is now strictly enforcing a long standing rule that requires a legible signature on all clinic notes, orders, and other documentation (e.g. procedure notes) used to substantiate a claim billed to Medicare. Section 1833(e) of the Social Security Act states that contractors must be able to identify the provider who performed the service in order to pay.

CMS defines a legible signature or electronic signature as the appropriate ways of identification. Failure to have a written or electronic signature on these items will result in a denial regardless of the medical necessity.

All Medicare providers billing Medicare for service shall ensure that their signature is attached to these documents. Each provider should immediately put into place a protocol to assure these items are signed within a reasonable time frame, usually 48-72 hours after the encounter but certainly before the claim is submitted. If a physician written signature is not legible, and many are not, please include a signature sheet with any submissions to the CERT carrier or the RAC carrier. This sheet should include the physician’s written signature and his/her legible printed or typed name. If others have made entries on the items submitted it is recommended that they be included on this signature sheet. Scrawled illegible initials will not suffice, but clear, legible initials accompanying a typed or printed name will usually be acceptable with the initials noted on the signature sheet. Electronic signatures should clearly show that the item has been electronically signed and include a date and, if possible, a time. Providers should act quickly to adhere to this Medicare Program requirement to prevent unnecessary denials or delays in payment for appropriate services.

***********************************************************************************

As a standard of your practice, you should ensure that not only has the documentation been recorded, but signed off on as well. You may need to review your coding/billing processes to accomodate this. My understanding is that this will be enforced, but I am not sure how CMS plans on enforcing this issue. They may review this simply through your CERT audits, or through random pre-and post-payment audit processes.

The bottom line is to make sure that the PHYSICIAN SIGNATURE on the documentation is appended PRIOR to your claim submission.

FYI: the physician signatures and initials should be legible. This presents you and your physician with another "learning opportunity". Happy Coding!!!