Take a little-known Medicare transmittal, add ambiguity and some hope of a delayed effective date, and what do you have? A lot of confusion about how to proceed with changes that could affect your claims and compliance record.
"The news about signature requirements has been like the news with NPIs lately; it changes with the weather," says Kim Skehan of the Connecticut Association for Home Care. To play it safe, keep the following tips in mind:
1. Stop accepting physician stamped signatures for all orders and hospice certifications of terminal illness. If the Centers for Medicare & Medicaid Services comes through with an extension for compliance with the new requirement, you'll be ahead of the game.
2. Stop worrying if you allow electronic signatures for hospice certifications of terminal illness (CTIs). In spite of advice to the contrary earlier this month, CMS told industry representatives Jan. 15 that electronic signatures would be accepted for CTIs.
3. You can also accept faxes of hospice certifications--as long as the physician hand-signed the original. CMS clarified its position on such faxes after the Jan. 9 Open Door Forum.
4. Electronic signatures are also OK on orders and other documentation. CMS' clarification "will permit hospices to obtain either faxed or electronic physician signatures for the certification of terminal illness as well as all other required signatures," [which is] "the same standard that is applied to all other Medicare providers," the National Association for Home Care & Hospice says in a recent bulletin to members.