Signature requirements — guidelines for authentication of Medicare services

CMS requires that any Medicare service provided or ordered must be authenticated by the author — the one who provided or ordered that service. Authentication may be accomplished through the provision of a hand-written or an electronic signature; however, stamp signatures are unacceptable.

In addition, any documentation submitted to substantiate the medical necessity for a service billed to Medicare must clearly identify the patient, date of service, and the provider of the service. The purpose of the authentication (signature) requirement is to ensure that the services rendered have been accurately and appropriately documented, reviewed, and authenticated.

Summary of signature guidelines — acceptable forms of authentication The following methods of authentication have been deemed acceptable by CMS:

• Handwritten signature — a mark or a sign placed on a medical document to signify knowledge, approval, acceptance, or obligation by the individual who provided or ordered the services specified in the medical entry. Requirements for this form of authentication are dependent upon whether the signature is considered legible or illegible.
  • Legible signature — acceptable forms of presentation:
  • Legible full signature
  • Legible first initial and last name
  • Initials placed above a typed or printed name
  • Initials accompanied by a signature log — lists the typed or printed name of the author associated with initials or an illegible signature. Signature logs may be included on the page where the initials or illegible signature is used, or it may be submitted as a separate document.
  • Initials accompanied by an attestation statement — must be signed and dated by the author of the medical record entry, must be associated with a specific medical entry, and must contain sufficient information to identify the beneficiary.
  • Note: An unsigned handwritten note may be accepted as authentication when other entries on the same page are in the same handwriting and have been signed.
  • Illegible signature — acceptable forms of presentation:
  • Illegible signature placed above a typed or printed name
  • Illegible signature where the letterhead, addressograph, or other information on the page indicates the identity of the individual who signed the entry. For example, the provider’s name could be circled to indicate the identity of the individual who signed the entry.
  • Illegible signature accompanied by a signature log — lists the typed or printed name of the author associated with initials or an illegible signature. Signature logs may be included on the page where the initials or illegible signature is used, or it may be submitted as a separate document.
  • Illegible signature accompanied by an attestation statement — must be signed and dated by the author of the medical record entry, must be associated with a specific medical entry, and must contain sufficient information to identify the beneficiary.
• Electronic signatures — an electronic sound, symbol, or process attached to or logically associated with an electronic medical record to signify knowledge, approval, acceptance, or obligation by the individual who provided or ordered the services specified in the medical entry.
  • Electronic signatures must be authenticated, safeguarded against misuse and modification, and should be easily identifiable as electronic, rather than typewritten, signatures.
  • As the individual represented by the electronic signature bears responsibility for the authenticity of the information, physicians are strongly encouraged to check with their attorneys and malpractice insurers regarding the use of alternative signature methods.