Ophthalmology and Optometry Coding Alert

Resolving your questionable signatures prior to claim submission is key.

Here’s why: Medicare’s signature guidelines mandate that providers who furnish or order a service verify it in the record via their signature.

Deciphering these rules can be tricky, so we’ve put together this handy guide to help clear up some of the confusion. Read on to learn the hard and fast rules of acceptable Medicare signatures.

Rule 1: Medicare Has Guidelines That Provider Signatures Must Meet

Medicare requires that all services provided or ordered be authenticated by the author of the medical record. The appropriate method used for authenticating is either a handwritten or electronic signature.

Take a look at some examples of medical records requiring a signature:

• Dictated reports
• Lab/diagnostic orders/requisitions
• Certificates of medical necessity
• Treatment plans/plan of care
• Treatment log notes
• Outpatient and inpatient visits

Remember: Double-check signatures for dates. “All signatures must be dated,” and all “handwritten signatures must be hand dated,” Medicare Administrative Contractor (MAC) Palmetto GBA notes in guidance on its website (www.palmettogba.com).

Rule 2: Medicare Has a Specific Definition for an Acceptable Handwritten Signature

Medicare defines a handwritten signature as “a mark or sign by an individual on a document to signify knowledge, approval, acceptance, or obligation.”

If the provider’s signature is illegible, you may type or print the name below the signature.

Rule 3: Medicare Has Strict Rules on Acceptable E-signatures for Telehealth Visits

Electronic signatures are valid — with some stipulations, indicates the Centers for Medicare & Medicaid Services (CMS).

First, it’s critical to understand that you can’t just generate a signature with your electronic health record (EHR). Your practice’s tech systems should have robust safeguards against e-signature alterations, in line with existing signature legislation.

Also, “the individual’s name on the alternate signature method and the provider accept responsibility for the authenticity of attested information,” reminds the Medicare Learning Network (MLN) fact sheet “Complying with Medicare’s Signature Requirements,” which can be accessed at www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/mln-publications-items/cms1246723.

Additionally, Part B medications — “other than controlled substances” — should be ordered through an e-prescribing system, CMS guidance says.

If you’re unsure which types of e-signatures CMS accepts, take a look at a few of these examples:

• “Validated by” with provider’s name
• “Released by” with provider’s name
• “Electronically signed by” with provider’s name
• “Verified by” with provider’s name
• “Authorized by: John Smith, MD”
• “Digital signature: John Smith, MD”
• “Electronically approved by” with provider’s name

Tip: CMS encourages providers to check with attorneys and malpractice insurers to be sure their electronic signatures meet all the standards and regulations insurers have put forth.

Rule 4: You Are Allowed To Use a Stamped Physician Signature Under Certain Circumstances

Medicare will allow stamped signatures only under very special circumstances, such as cases of authors with a physical disability, in accordance with the Rehabilitation Act of 1973. The author with a physical disability must validate their signing inability. By using the rubber stamp, the provider confirms they’ve reviewed the document.

Rule 5: Illegible Signatures Bust Be Submitted With Additional Documents for Payment

In some cases, your provider’s signature may be illegible. If this happens, submit a signature log or an attestation statement with the claim. Signature logs and attestation statements support the identity of the individual who provided the illegible signature. Doing this will help avoid delays in the review process.

Tip: If you choose to submit an attestation statement when your provider’s signature is illegible, keep in mind that for Medicare to consider the attestation statement valid, the author of the medical record entry must sign and date the statement. The statement must also include the appropriate patient information.

Caution: You can’t simply include a blank attestation statement with no patient identification information. The statement must be personalized for each patient and signed by the physician.

Rule 6: Always Keep a Signature Log

A signature log is a typed listing of the provider or providers identifying their name(s) with a corresponding handwritten signature(s). The provider’s credentials are required, and the signature log must be part of the patient’s medical record.

Don’t miss: You may include the signature log on the same page where the initial or illegible signature is located or in a separate document. Just make sure that the signature log is a part of the patient’s medical record.