Failure to comply with Medicare signature and authentication rules is a frequent cause of claims denials. In January, CMS revised its Medicare signature guidelines to incorporate new rules for electronic signatures.
Acceptable signatures include handwritten signatures or initials, as well as electronic signatures. The latter typically include date and timestamps and printed statements, “electronically signed by” or “verified/reviewed by,” followed by the practitioner’s name and a professional designation. Also acceptable are digital signatures, or a written signature typically generated by encrypted software, allowing sole usage. The revised CMS guidance clarifies that electronic signatures, including an electronic sound, symbol, or process attached to, or logically associated with an electronic medical record, must be:
- Safeguarded against misuse and modification; and
- Easily identifiable as electronic instead of a typed signature.
The electronic signature represents the provider who signed it, the guidance explains, and that individual is responsible for its authenticity. CMS “strongly encourages” physicians and NPPs to check with their attorneys and malpractice insurers when using electronic signatures as an alternate signature method.