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Who Signed This Prescription?
Written by: Stacy Toner & Ashley Zaikowski
Have you ever received a prescription or a document and passed it to your coworker asking, “do you know who signed this?” Sometimes you receive a clear signature, but all too often the signature is unrecognizable. A common question we receive is, “the signature on the documentation I received from my referral source is illegible, how can I prove it is the doctor who signed the document”? Illegible signatures are an issue every provider runs into at some point. Here’s how to prepare for and handle the situation.
The CMS signature requirements are found in the Program Integrity Manual Chapter 3 section 184.108.40.206. The section outlines what medical reviewers will accept for signatures, how to authenticate an illegible signature and there is also an extremely helpful chart for determining whether a signature is compliant.
When there is an illegible signature on a document the provider should follow what CMS calls the “signature authentication process”; which can be completed through either a Signature Log or an Attestation Letter.
A Signature Log is documentation that shows both the signatory’s printed or typed name and the illegible signature. The Signature Log can be either a separate document or right on the document where the original illegible signature is. In the case of a Signature Log, the reviewer of the documentation will consider the authentication no matter the creation date. In other words, if your illegible signature is dated 01/15/2019 and the Signature Log was created on 02/18/2019, it will still be considered in a medical review.
The second authentication process is a Signature Attestation Statement. This document must be signed and dated by the signatory and must have enough information to identify the patient. While CMS does not have an approved format for the Signature Attestation Statement, they do provide an example in the Signature Requirements policy.
Lastly, in the Signature Requirements policy you will find a helpful signature guidelines chart that outline whether a signature has met the requirements. It is important to note that this section of the policy states that it applies to the MACs, CERT and ZPIC/UPIC auditor (the RACs are not listed). It is indicated in the policy that when a signature is found to be non-compliant, the reviewer is to contact the billing provider to ask for a signature authentication. The provider then has twenty (20) days to submit the authentication; at which point the reviewer must complete the medical review within fifteen (15) days from the date the authentication is received.
Receiving an order or document with an illegible signature is a tricky situation that we will all find ourselves in from time to time, however with the CMS Signature Requirements policy it doesn’t have to be a difficult problem to fix! A great way to get ahead of the issue is to train everyone in your facility on the CMS’ Signature Requirements policy; when an illegible signature comes across anyone’s desk, they will know how to properly authenticate it. A full review of the policy and the chart provided for signature requirements can be found here.
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