Medicare Physician Signature Requirements

In 2006, the Centers for Medicare and Medicaid Services initiated the Recovery Audit Contractor (RAC) program to contain healthcare costs by minimizing incorrect and inappropriate payments made within the Medicare system. The program is also designed to identify means of improving the system to minimize future payment problems. In response to the increased scrutiny of the review process, CMS guidelines adopted requirements for physician signatures which identify correct and incorrect practices.
  1. Purpose and Basic Requirements

    • The doctor or individual who provided or ordered the services must be identified in the patient's medical records. This confirms that the provider has deemed the services as medically necessary. Each signature is required to be legible with the medical provider's first and last name. Credential (such as M.D. or D.O) should also be included.

    Acceptable Signatures

    • Handwritten signatures, handwritten initials and electronic signature methods are acceptable for use on test orders or medical records. Electronic signatures should be in the form of a digitized signature, electronic signature or digital signature. Digitized signatures are electronic images of the actual handwritten signature which is then reproduced with a pen tablet. Electronic signatures should contain the date, timestamp and a printed statement (such as "electronically signed by"). Digital signatures are another electronic signature method which is created by specialized software.

    Unacceptable Signatures

    • Signature stamps are not accepted as a valid signature. The use of a signature stamp may result in payment delays or denials. Transcription of records or reports which do not include a valid signature will be denied for reimbursement. Additional unacceptable signatures include writing "signing physician" with the physician's name typed and "signature on file."

    Signatures for Shared Services

    • In an office setting, there may often be a shared encounter with the patient and a non-physician practitioner (such as a physician assistant or a certified nurse midwife). Services in these circumstances are designated as having been performed "incident to" and must be signed by the physician. "Incident to" means that the medical services/supplies have been provided as an integral part of the physician's services. If the conditions to meet the "incident to" requirement are not met, or if the non-physician practitioner completed the entire service, the medical record should be signed by the non-physician practitioner.

    Surgical Assistants/Co-Surgeons

    • Surgical assistants are not required to sign the operative report as long as the report is signed by the primary surgeon. Co-surgeons are required to sign individually with an acceptable signature.

    Unavailable Medical Providers

    • If the medical provider works in a group practice and has either passed away or left the practice, one of the other medical providers working in the practice may sign on his behalf. Additional information must be included such as "Robert T. Jones, M.D. relocated to Utah on 12/01/10 and was unable to sign this medical record."

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