On May 17, 2013, CMS issued a clarification on the signature requirements for Medicare claims.  For medical review purposes, Medicare requires that an order for items or services be authenticated by the author. Medicare requires a handwritten or electronic signature.  Generally, stamped signatures are not acceptable.

The purpose of this change request is to permit the use of a rubber stamp for signature ONLY in those cases where authors with physical disabilities can provide proof to a CMS contractor of the inability to sign their signature due to their disability.  Medicare Program Integrity Manual, Pub 100-08, Transmittal 465, Change Request 8219, Effective Date: June 18, 2013.  The change is to MPIM Section 3.3.2.4 on Signature Requirements.  The change is stated to be in accordance with the Rehabilitation Act of 1973.  The Transmittal notes that this section is applicable for MACs, CERT, and ZPICs, but does not apply to Recovery Auditors.

The clarification of this section of the MPIM provides a good opportunity for providers and suppliers to review the complex and exception laden rules on signatures.  This section is important reading because the validity and timeliness of signatures is often an issue arising in audits of claims and is a frequent source of denials.  This section also addresses when signature attestations may be accepted by auditors and what evidentiary value attestations may be given.  The MPIM includes a chart to assist in determining whether to consider the signature requirements met. 

For a copy of Change Request 8219, click here.

Reporter, Donna K. Thiel, Washington, D.C., +1 202 626 2393, dthiel@kslaw.com.