Eli's Hospice Insider

Published on Mon Jan 30, 2017 PDF

CGS rescinds hasty policy interpretation.

Put one more time point on your list of deadlines to monitor.

In a Dec. 12 post on its website, HHH Medicare Administrative Contractor CGS explained how its Part B Medical Director gave an opinion on a two-day signature requirement for electronic medical records. “This internal guidance … will be rescinded,” the MAC says. “It has been determined that providers need a few days to reconcile their records. This reconciliation includes receiving labs, x-ray reports, consultation reports, and other aspects that ensure a completed visit note.”

However: “Reason would dictate that 10 working days should be ample time to finalize a visit note and sign/authenticate it,” CGS continues. “If there is a delay past this reasonable timeframe, an attestation should be submitted with appropriate documentation.”

“CGS expects providers to complete the documentation, including signatures, at the time of the service in order to maintain an accurate medical record and it is expected that an attestation be used for documentation containing late, missing, or illegible signatures,” the MAC continues. “Claims submitted on or after 12/12/2016, will be adjudicated according to this change.”

The article is at http://cgsmedicare.com/articles/cope1361.html. A CGS educational tool, “Signature Guidelines for Home Health & Hospice Medical Review,” is at www.cgsmedicare.com/hhh/medreview/sig_guidelines.pdf.