Oncology & Hematology Coding Alert

Don't waste your time appealing a denial due to a technicality.

The Medicare Program Integrity Manual (PIM) rule requiring physicians who order patient services to personally sign those orders is not new, but providers are starting to see denials citing such technicalities. Medicare Administrative Contractors (MACs) are enforcing the rule when denying Medicare payment for orders in instances where the authoring physician did not sign the order.

If, for example, a nurse practitioner (NP) signs an order an oncologist gave verbally, the MAC may deny Medicare payment because the authoring physician did not sign the order.

"This is one of the top reasons for Medicare denials," Maher says.

The good news:  You can prevent future denials of the same vein by adjusting your order processing and documentation across the board.

The bad news: Attestations are not allowed for physician's orders, making this particular denial very difficult to appeal, says Carol Maher, RNC, RN-BC, RAC-CT, RAC-MT, CPC, director of education at Hansen Hunter & Co. P.C. in Vancouver, Washington.

Take note of the specific information the Medicare Program Integrity Manual (Revision 713) tells MACs in 3.3.2.4 - Signature Requirements: "Reviewers shall NOT consider attestation statements from someone other than the author of the medical record entry in question (even in cases where two individuals are in the same group, one should not sign for the other in medical record entries or attestation statements)."

Take note: "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."

"I find that electronic orders are also problematic," Maher says. "Be sure that your nurses are carefully entering the name of the physician/NPP who is giving them a verbal or telephone order, because only the practitioner who gave the order can sign that order."

Your first (and most important) step should be educating staff, especially physicians and nonphysician providers (NPP), about this rule and how its recent enforcement will result in Medicare denials or recoupments.

Take a look at all of your systems for procuring orders, and make sure they are conducive to accurate, legible, and timely documentation - including the necessary signatures.

The bottom line: Whoever authors an order should sign the order, Maher says.