Meet Signature Requirements for Medical Review

The Centers for Medicare & Medicaid Services’ (CMS’) policy Change Request (CR) 6698 clarifies and updates signature guidelines for medical review purposes of the Program Integrity Manual (PIM).

Medicare claim review contractors measure, detect, and correct improper payments in the fee for service (FFS) Medicare program. Claims review contractors include:

  • Carriers
  • Fiscal intermediaries called affiliated contractors (ACs)
  • Medicare administrative contractors (MACs)
  • The comprehensive error rate testing (CERT) contractor
  • Recovery audit contractors (RACs)

Prior language in the PIM required a “legible identifier” (a handwritten or electronic signature) for every service provided or ordered. Effective March 1, CR 6698 updates these requirements and adds e-prescribing language.

The majority of changes are in section 3.4.1.1 – Documentation Specifications for Areas Selected for Prepayment or Postpayment MR. Areas with extensive updates are:

B. Signature Requirements

1. Handwritten Signatures

a. Signature Log

b. Signature Attestation Statement

c. Signature Guidelines

2. Electronic Signatures

3. Electronic Prescribing

a. E-Prescribing for Part B Drugs (Other than Controlled Substances)

b. E-Prescribing for Part B Controlled Substance Drugs

c. E-Prescribing for Drugs Incident to DME

G. Additional Signature Requirements for DMEPOS

H. Signature Dating Requirements

I. ADR Language Regarding Signatures

J. Fraud Referrals

In regard to these changes, Vice President of AAPC Business and Member Development Rhonda Buckholtz, CPC, CPMA, CPC-I, CGSC, COBGC, CPEDC, CENTC, said “Page 9 holds the most significant information,” in the B. Signature Requirements portion, which states:

“All signature requirements in this CR are effective for CERT reviews retroactively for the November 2010 report period. All signature requirements for ACs, MACs, PSCs and ZPICs are applicable for reviews conducted on or after 30 days after the issuance of this CR.”

According to Buckholtz, “Providers who have not met signature requirements in the past are at risk because this is retroactive. This may also significantly affect RAC audits.”

For further details, read CR 6698 on the CMS website.

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