General Surgery Coding Alert

Resolving your questionable signatures prior to claim submission is key.

In your general surgery practice, it’s likely that you encounter Medicare patients regularly mastering the skill of avoiding claim denials due to signature errors is crucial.

Here’s why: Medicare mandates that services provided or ordered must be verified by the author. Verification can be achieved through a handwritten or electronic signature.

Read on to learn the hard and fast rules of acceptable Medicare signatures.

Rule 1: Medicare has guidelines that provider signatures must meet.

Medicare requires that all services provided or ordered be authenticated by the author of the medical record. The appropriate method used for authenticating is either a handwritten or electronic signature.

Take a look at some examples of medical records requiring a signature:

• Dictated reports
• Outpatient visits
• Lab/diagnostic orders/requisitions
• Treatment plans/plan of care
• Treatment log notes
• Inpatient visits
• Office visits

Remember: Double-check signatures for dates. “All signatures must be dated,” and all “handwritten signatures must be hand dated,” Medicare Administrative Contractor (MAC) Palmetto GBA notes in guidance on its website (https://www.palmettogba.com).

Rule 2: Medicare has a specific definition for an acceptable handwritten signature.

Medicare defines a handwritten signature as “a mark or sign by an individual on a document to signify knowledge, approval, acceptance, or obligation.”

If the provider’s signature is illegible, you may type or print the name below the signature.

Rule 3: Medicare has strict rules on acceptable e-signatures for telehealth visits.

Electronic signatures are valid — with some stipulations, indicates the Centers for Medicare & Medicaid Services (CMS).

First, it’s critical to understand that you can’t just generate a signature with your electronic health record (EHR). Your practice’s tech systems should have robust safeguards against e-signature alterations, in line with existing signature legislation.

Also, “the individual’s name on the alternate signature method and the provider accept responsibility for the authenticity of attested information,” reminds the Medicare Learning Network (MLN) fact sheet “Complying with Medicare’s Signature Requirements,” which can be accessed at: https://www.cms. gov/outreach-and-education/medicare-learning-network-mln/ mlnproducts/mln-publications-items/cms1246723.

Additionally, Part B medications — “other than controlled substances” — should be ordered through an e-prescribing system, CMS guidance says.

If you’re unsure which types of e-signatures CMS accepts, take a look at a few of these examples:

• “Validated by” with provider’s name
• “Released by” with provider’s name
• “Electronically signed by” with provider’s name
• “Verified by” with provider’s name
• “Authorized by: John Smith, MD”
• “Digital signature: John Smith, MD”
• “Electronically approved by” with provider’s name

Tip: CMS encourages providers to check with attorneys and malpractice insurers to be sure their electronic signatures meet all the standards and regulations insurers have put forth.

Rule 4: You are allowed to use a stamped physician signature under certain circumstances.

Medicare will allow stamped signatures under very special circumstances, such as cases of authors with a physical disability, in accordance with the Rehabilitation Act of 1973. The author with a physical disability must validate their signing inability. By using the rubber stamp, the provider confirms they’ve reviewed the document.

Rule 5: Illegible signatures must be submitted with additional documents for payment.

In some cases, your provider’s signature may be illegible. If this happens, submit a signature log or an attestation statement with the claim. Signature logs and attestation statements support the identity of the illegible signature.

Tip: You can submit an attestation statement if your provider’s signature is illegible. For Medicare to consider an attestation statement valid, the author of the medical record entry must sign and date the statement. The statement must also include the appropriate patient information.

Caution: You can’t simply include a blank attestation statement with no patient identification information. The statement must be personalized for each patient and signed by the physician.

Rule 6: Always keep a signature log.

A signature log is a typed listing of the provider or providers identifying their name(s) with a corresponding handwritten signature(s). The provider’s credentials are required, and the signature log must be part of the patient’s medical record.

Don’t miss: You may include the signature log on the same page where the initial or illegible signature is located or in a separate document. Just make sure that the signature log is a part of the patient’s medical record.

A signature log can be created at any time and MACs will accept all submitted signature logs, regardless of the date they were created.

Review this helpful chart to determine whether you’ve met the signature requirements dictated by CMS: