Wiki Signature Question

[TracyAlder]

Does the signature need to contain the provider's credentials in order for it to be valid? Or is it enough that the provider's credentials are noted elsewhere in the visit note?
Thanks so much!

 

[amyjph]

They should always sign with full signature and credentials. This way there can be no question later.

 

[sls314]

If it is a handwritten signature or initials over the provider's typed name/credentials, that could be permissible.

The Medicare Program Integrity Manual has a section on signature requirements which gives specific information about requirements for both handwritten and electronic signatures. An example of what I stated above is included in the manual - it contains a chart with several very specific examples.

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/pim83c03.pdf

There is also an MLN article on Complying with Medicare Signature Requirements:

https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/signature_requirements_fact_sheet_icn905364.pdf

Agree with Amy that it's best to be as clear as possible so that there's no chance of question later.

 

[sathiya]

Hi Susan,

Thank you. Can you confirm co-sign is mandatory for incident to billing

 

[csperoni]

Hi Susan,

Thank you. Can you confirm co-sign is mandatory for incident to billing

Physician co-signature is not required by most MACs under most scenarios. I'll have to see if I can find the reference, but I did once come across a specific MAC stating for non-billable provider incident-to (meaning 99211 for nurse), then the physician should also sign.
This is my MACs (NGS) guidelines stating on page 47 that the supervising physician does NOT need to sign

https://www.ngsmedicare.com/documents/20124/121705/1820_0122_signature_guidelines_2022_508.pdf/21a273c7-2c2f-828a-2bfa-0ff80e69c1b7?t=1642772025447

 

[csperoni]

Found it!! Palmetto GBA specifically states for incident-to, NPP notes do NOT need to be co-signed by physician, but ANCILLARY staff notes do require physician signature.

https://www.palmettogba.com/palmetto/jmb.nsf/DIDC/8EEM4Q2610~Medical%20Review

I do not recall ever seeing another MAC stating this, and was rather surprised when I originally came across it.
I will note that sometimes employers have additional requirements above and beyond CMS and a specific employer may require it.
From a logistics standpoint, one subspecialty practice I work with has many clinicians working in several locations. We have the onsite MD sign all ACP notes, otherwise it is almost impossible to know later who might have supervised a particular service. IF the visit meets all other incident-to, AND the carrier follows incident-to, the co-signature lets the coder know who to put the bill under.