ED Coding and Reimbursement Alert

Question: We have problems with one of our ED doctors who orders lab tests and doesn't sign the orders. He will sign them sometimes and not others. Fortunately, the lab usually catches the issue and returns the orders for signature, but not always. What can we do?

Codify Subscriber

Answer: You can alert the physician that order signature rules are being enforced by MACs more often, resulting in higher claim denials, and advise him that a lack of a signature could lead to lower reimbursement.

Background:  CMS requires physicians who order therapy, lab tests, or other patient services to personally sign orders, but practices are starting to see an uptick in denials related to such technicalities. And as Medicare Administrative Contractors (MACs) continue to earmark documentation fauxpas in their Targeted Probe and Educate (TPE) reviews, it's essential for practices to work together to eradicate instances where the authoring physician did not sign the order.

Such situations can arise pretty easily, especially when colleagues verbally discuss therapy or other care options with a patient and forget to cross the t's and dot the i's. If, for example, a nurse practitioner signs a therapy order that a physician gave verbally, the MAC may deny Medicare payment for that therapy because the authoring physician did not sign the order.

Reminder:  "For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author," the Medicare Program Integrity Manual says. "The method used shall be a handwritten or electronic signature. Stamped signatures are not acceptable."

CMS clearly outlines what constitutes a "valid signature." According to the agency's guidance, you should consider these three questions before you send over your Medicare claims:

• Are the ordered and/or performed services properly authenticated by the ordering provider?
• Are the signatures handwritten or electronic in nature? (Note that stamped signatures are acceptable in cases where the Medicare provider has a documented disability that is known to the MAC and impedes a handwritten or electronic signature).
• Is the signature legible?

If the physicians in your ED group don't meet these criteria, schedule an educational session where you discuss what the practitioners must do to meet the requirements.