Wiki Signature Question

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TracyAlder

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Does the signature need to contain the provider's credentials in order for it to be valid? Or is it enough that the provider's credentials are noted elsewhere in the visit note?
Thanks so much!
 
If it is a handwritten signature or initials over the provider's typed name/credentials, that could be permissible.

The Medicare Program Integrity Manual has a section on signature requirements which gives specific information about requirements for both handwritten and electronic signatures. An example of what I stated above is included in the manual - it contains a chart with several very specific examples.


There is also an MLN article on Complying with Medicare Signature Requirements:


Agree with Amy that it's best to be as clear as possible so that there's no chance of question later.
 
Hi Susan,

Thank you. Can you confirm co-sign is mandatory for incident to billing
 
sathiya said:
Hi Susan,

Thank you. Can you confirm co-sign is mandatory for incident to billing
Click to expand...
Physician co-signature is not required by most MACs under most scenarios. I'll have to see if I can find the reference, but I did once come across a specific MAC stating for non-billable provider incident-to (meaning 99211 for nurse), then the physician should also sign.
This is my MACs (NGS) guidelines stating on page 47 that the supervising physician does NOT need to sign
 
Found it!! Palmetto GBA specifically states for incident-to, NPP notes do NOT need to be co-signed by physician, but ANCILLARY staff notes do require physician signature.
I do not recall ever seeing another MAC stating this, and was rather surprised when I originally came across it.
I will note that sometimes employers have additional requirements above and beyond CMS and a specific employer may require it.
From a logistics standpoint, one subspecialty practice I work with has many clinicians working in several locations. We have the onsite MD sign all ACP notes, otherwise it is almost impossible to know later who might have supervised a particular service. IF the visit meets all other incident-to, AND the carrier follows incident-to, the co-signature lets the coder know who to put the bill under.
 
I know this post is a little old, but I am hoping to get some assistance. Palmetto GBA states that NPP notes do not have to be co-signed by the physician for incident-to billing. Palmetto GBA’s incident-to guidelines state:

The documentation submitted to support billing “incident to” services must clearly connect the services of the NPP auxiliary staff to the services of the supervision physician.
  • Ensure the name and professional designation of the person rendering the service is legible in the documentation of each service
  • Legibly identify, credentials and co-signature (i.e., M.D., DO, NP, PA, etc.) of both the practitioner who provided the service and the supervising physician on documentation entries
  • Documentation from other dates of service, for example the initial visit establishing the connection between the two providers

Jurisdiction M Part B - Incident To: Physician's Professional Services

palmettogba.com palmettogba.com

Am I understanding this correctly, that while a co-signature is not required for incident-to, documentation has to clearly connect the NPP’s service to the supervising physician? And is one way to do that by the supervising physician co-sign the note?
 
That is how I am interpreting. In the link you provided, just above the bullet list, you left off the sentence "The connection may be evidenced by:" So co-signature is one way of supporting incident-to.
 
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