Signature Requirements New Medicare Guidelines

Transcription

1 From: Jurisdiction B DME MAC [mailto:dmemaclistserve@anthem.com] Sent: Monday, April 05, :10 PM Subject: Jurisdiction B News: Signature Requirements New Medicare Guidelines Signature Requirements New Medicare Guidelines CMS recently published instructions to contractors on signature requirements. Those requirements are found in the Medicare Program Integrity Manual, Chapter 3, Section They were effective for claims with dates of service on or after March 1, These guidelines apply not only to claims reviewed by the DME MAC but also to claims reviewed by the CERT contractor, Program Safeguard Contractor (PSC), and Recovery Audit Contractor (RAC). For medical review purposes, Medicare requires that all orders and medical records that are used in the adjudication of claims be authenticated by the author. The method used must be a legible handwritten full signature, handwritten initials, or electronic signature. Stamped signatures are not acceptable. Signature logs If the signature is illegible on an order or medical record, the physician/ practitioner may provide a signature log which includes the printed name of the author and the full signature or initials that appear on the document. Listing the credentials of the author is encouraged.

2 Attestation statements If the signature is missing on an order, the order will be disregarded and the claim will be denied. If the signature is missing from the medical records, the physician/practitioner may provide an attestation to verify the entry. Physicians/practitioners should not add late signatures to the medical record (beyond the short delay that occurs during the transcription process), but instead may make use of the attestation process. In order to be considered valid for Medicare medical review purposes, an attestation statement must be signed and dated by the author of the medical record entry and must contain sufficient information to identify the beneficiary. Should a physician/practitioner choose to submit an attestation statement, they may choose to use the following statement: I [full name of the physician/practitioner], hereby attest that the medical record entry for [Date of Service] accurately reflects notations that I made in my capacity as [insert provider credentials, e.g., M.D.] when I treated/diagnosed the above listed Medicare beneficiary. I do hereby attest that this information is true, accurate and complete to the best of my knowledge and I understand that any falsification, omission or concealment of material fact may subject me to administrative, civil or criminal liability. Attestation statements will not be accepted where there is no associated medical record entry. Attestation statements from someone other than the author of the medical record entry in question are not acceptable (even in cases where two individuals are in the same group, one may not sign for the other in medical record entries or attestation statements). Review guidelines The guidelines below will be used by National Government Services

3 reviewers in determining whether to consider the signature requirements met. Example Acceptable Not acceptable 1 Legible full signature 2 Legible first initial and last name 3 Illegible signature where the letterhead, addressograph or other information on the page indicates the identity of the signator. Example: An illegible signature appears on a prescription. The letterhead of the prescription lists 3 physicians names. One of the names is circled. 4 Illegible signature over a typed or printed name : 5 Illegible signature NOT over a typed/printed name and NOT on letterhead, but the submitted documentation is accompanied by: 1) a signature log, or 2) 6 Illegible Signature NOT over a typed/printed name, NOT on letterhead and the documentation is UNaccompanied by: a signature log, or 7 Initials over a typed or printed name 8 Initials NOT over a typed/printed name but accompanied by: a signature log, or 9 Initials NOT over a typed/printed name Unaccompanied by:

4 a signature log, or 10 Unsigned typed note with provider s typed name 11 Unsigned typed note without providers typed/printed name 12 Unsigned handwritten note, the only entry on the page 13 Unsigned handwritten note where other entries on the same page in the same handwriting are legibly signed 14 Signature on file 15 Notation of electronic signature The individual whose name is on the alternate signature method bears the responsibility for the authenticity of the information being attested to. Development letters Suppliers are encouraged to review the documentation that they submit in response to development letters to verify that the signature requirements are met. If they are not met, suppliers are encouraged to obtain a signature log or attestation statement, as applicable, and to submit that along with the documentation. If the reviewer determines that a claim is payable except for the signature requirements not being met, the medical review department will send a second development letter to the supplier providing the opportunity to submit a signature log or attestation statement. Suppliers will have 20 days from the date of the second development letter to respond. If an acceptable signature log or attestation statement is not received in that time frame, the claim will be denied. If the supplier chooses to appeal the claim denial, a signature log or attestation statement, as applicable, should be provided with the redetermination request.

5 If the reviewer determines that a claim is not payable for reasons other than the signature requirements not being met, the claim will be denied. A second development letter will not be sent in this situation. If the supplier chooses to appeal the denied claim and if there is an illegible or missing signature, a signature log or attestation statement, as applicable, should be provided with the redetermination request. Please refer to the Jurisdiction B DME MAC Supplier Manual for additional information regarding documentation requirements.