The Centers for Medicare and Medicaid Services (CMS) has made the criteria for prescribers’ signatures stricter and has added language regarding e-prescriptions to its signature guidelines for medical review. Change Request (CR) 6698, issued March 16, states that for claim-review purposes, Medicare’s Program Integrity Manual previously required “a legible identifier in the form of a handwritten or electronic signature for every service provided or ordered.” During claims review, the claims review contractors previously could request documentation from the provider to verify the signature. Now, every signature must be “authenticated by the author,” and claims reviewers may request documentation from third-party providers as well.
Specifically, if a prescriber’s signature is illegible and not accompanied by a typed, unambiguous indication of the prescriber’s name, the claims reviewers must now hold off on fulfilling the claim until they consider evidence for the signature’s validity. This evidence can include entries in a signature log, other signed documents in the claims paperwork, or an attestation statement from the prescriber. Attestation statements must be signed and dated by the author of the medical record entry and identify the beneficiary. CR 6698 includes a table of circumstances in which illegible signatures do and do not meet the new requirements, plus a sample attestation statement and instructions for when such a statement may not be used. If the signature requirement is unmet, the claims reviewer must now contact the biller for an attestation statement or signature log, which may be provided within 20 calendar days. The reviewer may also contact the provider for confirmation, which extends the review period for an additional 15 days.
The new guidelines will take effect on April 16.
