Home Health & Hospice Week

Surveyors, intermediaries hop on the stamped signature prohibition bandwagon.

Providers who've been surprised by the ban on stamped signatures from physicians had better get used to the idea or risk payment and compliance problems.

The Centers for Medicare & Medicaid Services, its surveyors and its contractors are all getting on the same page about the new signature requirements that CMS unveiled last summer and fine tuned this year (see Eli's HCW, Vol. XVII, No. 3).

"For home health providers, effective with dates of service beginning April 28, 2008 stamp signatures will no longer be accepted as a valid physician's signature for home health orders, including the plan of care," regional home health intermediary Palmetto GBA says in its June provider bulletin. "Claims with physician stamp signatures will be denied during the medical review process."

CMS also issued a May 30 survey & certification memo (S&C-08-22) insisting that "effective immediately, HHAs and hospices may not accept physicians' rubber stamp signatures for their clinical record documentation."

The change reflects "our efforts to promote consistency between our survey and certification policies and Medicare program integrity policies," CMS says. The change is part of CMS' "plan to institute necessary program safeguards aimed at combating fraud and abuse in the Medicare and Medicaid programs," the memo says.

Hospice highlight: CMS also issued a question-and-answer about physician signatures for hospice. The agency continues to get questions on the policy that was issued in a March transmittal, it notes.

The hospice must be able to produce a hard copy of a physician's signature, the Q&A reiterates. "If the hospice has as part of the patient's medical record, a facsimile, hard copy, copy of a facsimile, or copy of a hard copy signature, so long as the signature is legible and can be authenticated, the hospice has fulfilled the requirement of maintaining facsimile and hardcopies of physician signatures," CMS explains.

Note: The survey and certification memo is online at www.cms.hhs.gov/SurveyCertificationGenInfo/downloads/SCLetter08-22.pdf. For a copy of the hospice Q&A, email editor Rebecca Johnson at rebeccaj@eliresearch.com with "Hospice Signature Q&A" in the subject line.