As of May 17,
2013 - Medicare has clarified and
updated the usage of rubber stamps for signature on medical documentation, as
noted a transmittal from CMS (see links below) The big “take-away” from this is that
legible signatures need to be in place prior to billing services to Medicare. To ensure compliance with Medicare, I would encourage providers to sign all orders and documentation in a timely manner. Reimbursement is a critical factor for many practices, and this is an "easy" area to work on in your practice. Be sure to audit and review your documentation for compliance. Happy Coding! L : )
GENERAL SIGNATURE REQUIREMENTS
http://www.cms.gov/transmittals/downloads/R327PI.pdf
http://www.cms.gov/MLNMattersArticles/downloads/MM6698.pdf http://www.cms.gov/ContractorLearningResources/downloads/JA6698.pdf
http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R465PI.pdf
The general signature requirements state that services that are provided
to Medicare
Beneficiaries need to be authenticated by the author, for medical review.
If signatures
are illegible or missing from medical documentation (other than orders), a
signature log or attestation can be used to provide additional information to
the reviewer. However, orders without a
signature will be disregarded during the claim review.
Signatures cannot be “captured” after the fact through signature logs or
attestation. Refer to the transmittal
for detailed information on the signature log and attestation process.
NOTE: The
transmittal states: “If AC, MAC or CERT reviewers identify a pattern of
missing/illegible signatures it shall be referred to the appropriate PSC/ZPIC
for further development.”
NOTE: Stamp signatures are not acceptable Per Transmittal 465, stamped signatures are
acceptable only if the author has a physical disability and can provide proof
to a CMS contractor of his/her inability to sign their signature due to their
disability. The rubber stamp certifies that the provider has reviewed the
document.
NOTE: Any
notation of “signature on file” also does not meet the signature requirements
