MEDICARE PROGRAM INTEGRITY MANUAL ALLOWS FOR ELECTRONIC SIGNATURES FOR AUTHENTICATION
By: Florida Health Law Center
Greenspoon Marder
As of June 6, 2017, the Center for Medicare and Medicaid Services (“CMS”) will accept both handwritten and electronic signatures for authentication of medical services provided or ordered, as required by CMS’s Medicare Program Integrity Manual. However, stamped signatures are still not allowed. If the signature is illegible, evidence of the identity of the author from other sources will be used. If the signature is missing from any other medical documentation, the signature attestation from the author of the medical record entry will be accepted. If, however, the signature is missing from the order, the order will be disregarded.
The Medicare Program Integrity Manual cautions providers who use electronic systems of the potential for misuse or abuse of alternate signature methods. Providers should have system and software products in place to protect against modification, misuse, abuse, or other concerns, while implementing appropriate administrative procedures that meet recognized standards and laws. Both the individual’s name on the alternative signature and the provider are responsible for the authenticity of the information in the attestation.
The Medicare Program Integrity Manual may be found here.
For assistance with ensuring that your authentication methods and electronic medical records generally are compliant for Medicare purposes, please contact Lee Lasris, Jodi Laurence, or any other member of Greenspoon Marder’s Florida Health Law Center. They may be reached at (954) 491-1120.