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Medical Review Signature and Attestation Guidelines

For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. To ensure compliance with the Centers for Medicare & Medicaid Services (CMS) policy regarding signature requirements follow the instructions outlined in the CMS Pub.100-08, Program Integrity Manual, Chapter 3External PDF, Section 3.3.2.4.

Signature Requirements

Medicare services provided/ordered must be authenticated by the author by some form of signature. This includes orders and medical record documentation of all services provided. The signature must include the credentials of the individual and be dated. The method used shall be a hand written (may be faxed), or an electronic signature. Stamped signatures are generally not acceptable. CMS permits use of a rubber stamp for signature in accordance with the Rehabilitation Act of 1973 in the case of an author with a physical disability that can provide proof to a CMS contractor of his/her inability to sign their signature due to their disability. By affixing the rubber stamp, the provider is certifying that they have reviewed the document.

If the signature is illegible, evidence in a signature log or attestation statement or other documentation will be considered. If the signature is missing from an order, the order shall be disregarded during the review of the claim. If the signature is missing from any other medical record documentation, a signature attestation will be accepted from the author of the medical record entry.

Note: When a scribe is used by a provider in documenting medical record entries (e.g. progress notes), CMS does not require the scribe to sign/date the documentation. Items or services will not be denied because a scribe has not signed/dated a note.

Signature Log

Providers may submit a signature log that lists the typed/printed name of the author associated with initials or illegible signatures. The signature log may be included on the actual page where the initials or illegible signature is used or may be a separate document. The signature should include credentials of the individual.

Attestation Statements

The attestation statement must be signed and dated by the author of the medical record entry and must contain sufficient information to identify the beneficiary. Attestation statements will not be accepted where there is no associated medical record entry. An example of an acceptable attestation statement can be found in Chapter 3, Section 3.3.2.4 of the CMS Pub.100-08, Program Integrity ManualExternal PDF.

Attestation statements from someone other than the author of the medical record entry in question are not acceptable. Two individuals in the same group may not sign for the other in medical record entries or attestation statements.

An attestation after the date of service is acceptable in most cases.

Exception: when the relevant regulation, [national coverage determination (NCD), local coverage determination (LCD), and Centers for Medicare & Medicaid Services (CMS) manuals] has specific signature requirements, (e.g., signatures on plans of care must be signed prior to services being rendered), those signature requirements take precedence.

Signature Guidelines

The signature guideline table found in the Signature Guidelines for Home Health & Hospice Medical ReviewPDFQuick Resource tool provides guidance as whether or not medical review will consider the signature requirements are met. The guidelines define when the signature requirements are considered met and when medical review will contact the provider for additional information.

When additional information is requested via a second ADR request, the additional information must be received and processed by CGS within 15 days from the date of the second ADR request. If a response is not received, the claim will be reviewed using the original documentation submitted.

CMS Resources

Updated: 12.10.19

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