Signature Requirements

NHIC would like to remind providers of the current Signature Requirements as stated in Chapter 3 (3.4.1.1 ) of the Program Integrity Manual: Medicare requires a legible identifier for services provided/ordered. The method used shall be hand written or an electronic signature (stamp signatures are not acceptable) to sign an order or other medical record documentation for medical review purposes. NOTED EXCEPTION: Facsimile of original written or electronic signatures are acceptable for the certifications of terminal illness for hospice. Providers using electronic systems should recognize that there is a potential for misuse or abuse with alternate signature methods. Facsimile and hard copies of a physician’s electronic signature must be in the patient’s medical record for the certification of terminal illness for hospice. For example, providers need a system and software products which are protected against modification, etc., and should apply administrative procedures which are adequate and correspond to recognized standards and laws. The individual whose name is on the alternate signature method and the provider bears the responsibility for the authenticity of the information being attested to. Physicians should check with their attorneys and malpractice insurers in regard to the use of alternative signature methods. All State licensure and State practice regulations continue to apply. Where State law is more restrictive than Medicare, the contractor needs to apply the State law standard. The signature requirements described here do not assure compliance with Medicare conditions of participation. The link to CMS website for all manuals is https://www.cms.hhs.gov/manuals