Liles Parker PLLC
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ZPICs and PSCs are Enforcing Strict Medicare Signature Requirements

Medicare Signature Requirements(August 4, 2010):  Is your practice complying with Medicare signature requirements? Earlier this year, the Centers for Medicare and Medicaid Services (CMS) issued updated guidance, Change Request (CR) 6698, to be used by Medicare contractors (including Medicare Administrative Contractors, affiliated contractors, CERT contractors, ZPICs and PSCs) when conducting claims reviews of medical documentation submitted by Medicare providers.  CMS reportedly issued this guidance to “clarify and update” various sections of the Program Integrity Manual.  Importantly, this guidance is not intended to supplant any existing specific requirements that may be contained in LCDs or other CMS manuals which may address specific signature requirements (such as signature and timeliness requirements which must be made in connection with Treatment Plans or Plans of Care prepared by health care providers in both private pracice and in clinics.   Several examples of the strict approach that CR 6698 requires include:

  •  For medical review purposes, Medicare requires that services provided / ordered be authenticated by the author.  The method used shall be a hand written or an electronic signature.  Stamp signatures are not acceptable. 

Our comments:  Despite the fact that “stamp signatures” have been problematic for years, we are still seeing cases where a provider has continued to use a stamp of his signature on orders and at the end of record entries. Get rid of signature stamps in your office or clinic!  Contractors that may be looking for an excuse to deny your claims will readily do so if your have used a stamp instead of documenting your signature by hand. 

  •  If there are other reasons for denial, unrelated to signature requirements, the reviewer shall not proceed to signature authorization.  If the criteria in the relevant Medicare policy cannot be met but for a key piece of medical documentation which contains a missing or illegible assessment, the reviewer shall proceed to the signature assessment. 

 Our comments This requirement reinforces the fact that Medicare reviewers are required to assess the adequacy of medical documentation (and presumably of medical necessity), separate and apart from their review of the signature itself.  Once they determine that the medical documentation is otherwise acceptable for coverage purposes, then they will assess whether the signature meets applicable requirements.

  •  If the signature is missing from an order, ACs, MACs, PSCs, ZPICs and CERT shall disregard the order during the review of the claim.

 Our comments This requirement can be extremely harsh, especially when considering the fact that many claims depend on an initial order by a referring or ordering physician.  If in the absence of such an order, the claim will be denied, it becomes readily apparent that providers must be especially diligent in their review of orders to ensure that each one is properly signed.

 These examples represent only a few of the many examples and changes highlighted in CR 6698.  We strongly recommend that you review these changes with each of the providers in your practice or clinic to ensure that everyone is aware of how CMS expects its contractors to proceed when conducting medical reviews.

Should you have any questions regarding these changes to the signature requirements, don’t hesitate to contact us. Liles Parker attorneys have extensive experience representing health care providers in both post-payment and pre-payment audits.  Our attorneys are also experienced in assisting providers with the development and implementation of an effective Compliance Plan.  For a complementary consultation, you may call Robert W. Liles or one of our other attorneys at 1 (800) 475-1906.




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