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Further details related to signatures were published in Transmittal 327 of the Medicare Program Integrity Manual (100-08), released on March 16, 2010.The signature guidelines apply to reviews conducted by Medicare Administrative Contractors (MACs), CERT Contractors and Recovery Audit Contractors (RACs).But if the patient is in the emergency room at this time and the order is written at 11 p.m.and the patient is not transferred until midnight, what is the proper time to document?
A statement to “admit” the patient is generally acceptable for the inpatient order, but an indication in the order that inpatient status is intended is even stronger, such as “Admit as inpatient to unit 3.” For the purposes of certification, a verbal order is valid but it must be authenticated prior to discharge.Now, CERT requires evidence of the treating physician's intent to order tests, including signed orders and/or progress notes.Again, in the past, CERT would review available documentation, including physician orders, supplier documentation, and patient billing history, then apply clinical review judgment.Two recent publications issued by CMS clearly indicate that the organization is tightening its requirements for the documentation required to support medical necessity and mandated signatures on prescriptions and orders for services.The first publication is the "Improper Medicare Fee for Service Payments Report of November 2009." This report details the type and percentage of errors found in claims as determined by reviews performed under the CERT (Comprehensive Error Rate Testing) program.While there is currently no specified format or language for the attestation, a suggestion is included in the transmittal. If a signature is illegible, there must be a typed or printed name next to the signature.Initials are not acceptable as signatures without further documentation (attestation, signature log, typed or printed name next to the initials, etc.) This transmittal also defines acceptable electronic signatures for e-prescribing.Hospital systems across the country are looking to streamline their billing and collection processes to become more efficient and better compete in their markets.The challenge many face is how to turn the data ...Page 9 of this document describes changes in what is acceptable and not acceptable for documentation to support the medical necessity of services provided.Impact of the More Stringent Review Criteria In the past, CERT would review available documentation, including physician orders, supplier documentation, and patient billing history, then apply clinical review judgment.