Home Health & Hospice Week
Beware New E-Signature Requirements For Hospice
Don't overlook an important wrinkle in the new standards for electronic signatures in hospice.
Electronic signatures from physicians for hospice terminal illness certifications are acceptable, notes a recent transmittal from the Centers for Medicare & Medicaid Services. That includes faxes of e-signatures too, says March 28 Transmittal No. 248 (CR 5971).
Hospices were glad to hear CMS would accept e-signatures for this purpose, since CMS had earlier indicated they may not be OK (see Eli's HCW, Vol. XVII, No. 13).
Watch out: But a provision in the transmittal notes that "hard copies of a physician's electronic signature must be in the patient's medical record for the certification of terminal illness for hospice."
A MLN Matters article CMS released in mid-April (MM5971) underscores the point. "Please be sure to note however, that while a signature facsimile is acceptable ... it and hard copies of a physician's electronic signature must be present in the patient's medical record."
The question: Hospices with electronic records generally don't keep a hard copy of records, noted attorney Connie Raffa in the April 2 Open Door Forum for home care providers. Does CMS expect them to print out the e-signature and store it someplace, asked Raffa, with Arent Fox in New York City?
The answer: Yes, said CMS' Sandra Bastinelli in the forum.
"Requiring hard copies of signatures is problematical," maintains attorney Mary Michal with Reinhart Boerner Van Deuren in Madison, WI. It "needs to be addressed further with CMS," she says.
The newly clarified requirement "makes it difficult for those hospices that are creating systems of documentation that are designed to be all electronic," protests Janet Neigh with the National Association for Home Care & Hospice.
"If the entire record is electronic, it doesn't make sense to me that hard copies would have to be maintained as well," Michal tells Eli.
Home health agencies seem to still have plenty of questions on the signature issue. Regional home health intermediary Palmetto GBA will hold an "Ask-The-Contractor" teleconference on the topic May 6 to address some of those queries.
Note: The transmittal is online at www.cms.hhs.gov/transmittals/downloads/R248PI.pdf. The MLN Matters article is at www.cms.hhs.gov/MLNMattersArticles/downloads/MM5971.pdf.
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