Pathology/Lab Coding Alert

Chicken Scratch Won't Count

Learn what constitutes an acceptable signature, according to CMS.

You'll soon need to make sure physicians and non-physician practitioners (NPP) sign your paper lab requisitions if you want to get paid, but exactly what does that entail?

CMS provides specific guidance on what constitutes an acceptable "signature" for documents subject to review for Medicare payment or by an audit contractor. Make sure your documents measure up by complying with one of the following options:

1. Make Sure It's Legible

The simplest signature -- but most difficult to ensure -- is a legible full-name signature or a legible signature using first initial and last name.

Unfortunately, you won't find many physicians or NPP who have a legible signature, and you certainly won't want to stake your payment on it. That's when you'll turn to option 2.

2. Accept Printed Name with Scribble

If you can't count on ordering physicians and NPP to legibly sign requisitions, you do have an alternative. Other personnel, such as a circulating nurse, can print the full name of the ordering physician/NPP on the requisition. Then the physician/NPP can initial next to or above the full printed name. In this case, the initials do not have to be legible to count as a legitimate signature.

Alternatively, if you submit a signature log or attestation statement that identifies the signer of an illegible signature, you can meet the signature requirement that way.

Just do it: "No doubt getting referring physicians and NPP to comply with Medicare's new policy for acceptable paper requisition signatures will be difficult, but compliance is essential if pathologists and laboratories are to continue to be paid for their work," says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. and publisher of the Pathology Service Coding Handbook, in The Villages, Fla.

Resource: You can read the full instruction for signature requirements in Transmittal 327, Medicare Program Integrity Manual, CMS IOM 100-08, available at www.cms.gov/transmittals/downloads/R327PI.pdf, and the associated MLN Matters article at www.cms.gov/MLNMattersArticles/downloads/MM6698.pdf.

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