Pulmonology Coding Alert

Question: What are the necessary requirements for physician signatures? Are E-signatures equally acceptable as handwritten signatures? Is it advisable to use signature logs?

Minnesota Subscriber

Answer: Your physician must include either a handwritten or approved electronic signature to authenticate the services provided.

What is a valid signature? According to Medicare, a valid signature must:

• Authenticate services the practitioner provided.
• Be handwritten or electronic — unless the author has a physical disability that permits her from providing a signature. In these cases, the provider can use a stamped signature if she “can provide proof to a CMS contractor of an inability to sign due to a disability.”
• Be legible.

Signature log: For handwritten signatures, Medicare does allow practices to keep a “signature log” on file to identify the provider if the signature alone is not legible enough to identify the provider and their credential. A signature log is a typed list of all of your practice’s healthcare providers, which includes their names and a corresponding signature and sometimes their signature as initials as well.

E-signature caution: According to CMS, an electronic signature also is valid, with some stipulations. Your practice’s software/computer system must have protections against electronic signature modifications or other individuals being able to access the physician’s signature; these standards should be stringent enough to correspond with any current signature laws currently in place. The physician must have a password-protected signature authentication and validation process; and sharing passwords is prohibited.

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

Rendering providers/authors: All electronic signatures should be completed in a timely manner. The CMS Program Integrity Manual (Chapter 3, Section 3.3.2.4) addresses signature requirements in detail. When a signature is missing during a review by a Medicare program contractor, an attestation is allowed: “If the signature is missing from the medical documentation (other than an order), MACs, SMRC, and CERT shall accept a signature attestation from the author of the medical record entry.”

Signature attestations are not permitted for orders, however. According to the manual, “If the signature is missing from an order, MACs, SMRC, and CERT shall disregard the order during the review of the claim (e.g., the reviewer will proceed as if the order was not received).”