Signature guidelines — 20-day timeframe for additional documentation requests

Medicare claim review contractors, including the comprehensive error rate testing (CERT) contractors and recovery audit contractors, are tasked with measuring, detecting, and correcting improper payments in the Medicare fee-for-service (FFS) program. These contractors review claims and medical documentation submitted by providers.

The previous language in the Program Integrity Manual (PIM) required a “legible identifier” in the form of a handwritten or electronic signature for every service provided or ordered. Change request (CR) 6698 updates these requirements and adds e-Prescribing language.

In situations where the guidelines in the PIM indicate for a medical reviewer to contact the billing provider requesting to submit an attestation statement or signature log to authenticate a medical record, the provider must submit the attestation statement or signature log within 20-calendar days.
The 20-day timeframe begins when:

• The reviewer makes actual phone contact with the provider, or
• The reviewer’s request letter is received by the U.S. Postal Service

Signature log:

A signature log lists the typed or printed name of the author associated with initials or an illegible signature. The signature log may be included on the actual page where the initials or illegible signature are used or may be a separate document. Medical reviewers will encourage the listing of credentials in the log; however, CMS has instructed reviewers not to deny a claim for a signature log that is missing credentials.

Signature attestation statement:

The author of the medical record entry must sign and date the attestation statement in order to be considered valid for Medicare medical review purposes. The attestation statement must contain the appropriate information to identify the beneficiary in question.