Medicare Compliance & Reimbursement

Question: Electronic signatures seem like the easiest route to go with so many of our visits being performed virtually. What are Medicare’s rules on e-signatures?

Alabama Subscriber

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

First, it’s critical to understand that you can’t just generate a signature with your EHR. Your practice’s software and computer systems must have protections against e-signature modifications; moreover, these standards should be stringent enough to correspond with any current signature laws on the books.

Plus, “the individual’s name on the alternate signature method and the provider accept responsibility for the authenticity of attested information,” reminds the MLN fact sheet “Complying with Medicare’s Signature Requirements.”

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

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

• “Validated by” with provider’s name
• “Reviewed by” with provider’s name
• “Released by” with provider’s name
• Chart “Accepted by” with provider’s name
• “Electronically signed by” with provider’s name
• “Verified by” with provider’s name
• “Signed before import by” with provider’s name
• Digitalized signature: Handwritten and scanned into the computer
• “Authorized by: John Smith, MD”
• “Digital Signature: John Smith, MD”
• “This is an electronically verified report by John Smith, MD”
• “Authenticated by John Smith, MD”
• “Confirmed by” with provider’s name
• “Electronically approved by” with provider’s name
• “Closed by” with provider’s name
• “Finalized by” with provider’s name

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