Otolaryngology Coding Alert

Extra: The physician's credentials have a role to play, too.

Your CPT^® coding may be spick and span, but if you fail to fulfill your physician signature requirements, your claim could end up in hot waters. Getting your provider to sign up the patient's charts is a basic documentation prerequisite that calls for your relentless compliance.

Basic: The treating physician's signature serves as a legible identifier for the provided/ordered services. Payers require that the signature must be present in the documentation that is associated with your claim.

Check out the following Q&A and find out why stamped signatures just won't do you any good.

Get To The Bottom Of Handwritten vs. Electronic Signatures

Question 1: Some of our physicians use handwritten signatures on their charts and others prefer electronic signatures. Is either kind acceptable?

Answer 1: According to CMS documents, "Medicare requires a legible identifier for services provided/ordered." That "identifier" -- or signature -- can be electronic or handwritten, as long as the provider meets certain criteria. Legible first and last names, a legible first initial with last name, or even an illegible signature over a printed or typed name are acceptable. You're also covered if the provider's signature is illegible but is on a page with other information identifying the signer such as a typed name.

"Also be sure to include the provider's credentials," says Cindy Hinton, CPC, CCP, CHCC, founder of Advanced Coding Solutions in Franklin, Tenn. "The credentials themselves can be with the signature or they can be identified elsewhere on the note."

Example: Pre-printed forms might include the physician's name and credentials at the top, side, or end. All qualify as acceptable documentation as long as the coder or auditor can identify the provider's credentials.

You can also use a signature log to back up your physician's documentation. The log should contain each provider's printed or typed name and credentials, along with their signatures and initials. You can reference the signature log in order to verify a note that contains an otherwise unidentifiable signature. "This is an important resource when providers are signing notes that do not include their typed or pre-printed name," Hinton says. This signature log is part of your compliance manual/plan

Tip: Update signature logs at least once a year. Create separate logs by provider (physicians, CRNAs, AAs, residents, etc.) to help simplify tracking.

Watch out: Stamped signatures don't meet the CMS requirements. Because a signature stamp can be used by anyone who has access to the stamp, in essence it doesn't authenticate that the billing provider was the author of the supporting documentation. You can, however, use a typed or printed block print name below the provider's signature to clearly identify an illegible signature.

Don't Assume EMRs Cover Everything

Question 2: Our otolaryngology practice is in the process of switching completely to electronic medical records. Does that cover signature requirements for us?

Answer 2: Some coders -- or providers -- believe that electronic medical records (EMRs) do all the documentation work, but that's not necessarily the case. "Even electronic signatures must meet certain requirements," Hinton says. "Not all verbiage is created equal."

Considerations: As your providers incorporate EMRs in their everyday care, double check the electronic signature's wording. Does it say, 'Electronically signed by' or 'Authenticated by'? Does it include the date? "There are numerous ways of phrasing and formatting the electronic signature," Hinton says. "Verify that the format you're implementing is approved by CMS." (See CMS' most recent update on signature guidelines.)

This is how it works: The physician would log onto the web-based transcription system using her pre-assigned username and password to access the patient's records. Upon logging on, the physician would see a list of patient records that are pending approval (i.e., needs to be electronically signed). They could either review the records and edit as necessary, or e-sign them right away. To do this, she would only have to click the 'Sign' button. The electronic signature would appear as typed text bearing the physician's name (e.g., 'Electronically signed by Jane Doe, MD').

Warning: "Electronic signatures carry the potential for misuse or abuse," says Judith Blaszczyk, RN, CPC, ACS-PM, of Auditing for Compliance and Education in Leawood, Kan. "System and software products should be protected against unauthorized modifications." Electronic capabilities should also comply with recognized standards and laws; check with your healthcare attorney and/or malpractice insurer to confirm compliance