Optometry Coding & Billing Alert

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CMS Clamps Down on Physician Signature Requirement

CERT has contractors denying claims that would have squeaked by in 2008.

CMS has released its annual error report, and the results are startling -- a 7.8 percent error rate in fiscal year 2009, compared to just 3.6 percent in 2008.

The higher rate, however, is not necessarily due to more incidences of fraud in the Medicare program, CMS indicated in its summary of the Comprehensive Error Rate Testing (CERT) results. Instead, the rate reflects a new methodology in calculating errors in Medicare claims, which "provides a more accurate assessment" of the errors. All told, the CMS report noted that the national paid claims error rate in Medicare's fee-for-service program equated to $24.1 billion during the review period. The agency's new methodology includes  a more "strict adherence to policy documentation requirements, signature legibility requirements, the removal of claims history as a valid source for review information, and the determination that medical record documentation received only from a supplier is, by definition, insufficient to substantiate a claim."

Signature rules: CMS asked its CERT contractor to more strictly adhere to its policy requiring that "services provided/ordered be authenticated by a legible identifier."

With CMS looking more carefully at signatures, some practices have voiced concern because their physicians routinely fail to sign their documents and often use stamps. "I never recommend stamped signatures," says Suzan Berman, CPC, CEMC, CEDC, senior manager of coding and compliance with the University of Pittsburgh Medical Center. "As a matter of fact, I discourage it on several different counts."

CMS says that there must be documentation showing that the doctor is the only one with access to his or her own signature stamp, Berman says. "With the increased use of electronic records, auditors are accepting the electronic signature or a legible signature of the provider. The auditors want to clearly be able to identify who performed the service. The doctors should try to sign their records in a timely fashion and at regular  intervals." To read the complete list of CERT results, visit the CMS Web site at www.cms.hhs.gov/cert.

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