Medical Review - CERT Eyes Physician Signatures

If you want to stand up under Medical review, have the doctor's signature on the Plan of care (POC) prior to billing.

Getting the doc's signature on the POC rule is a long-standing home health billing requirement; however, it can get overlooked in day-to-day practice. Now is the time to ratchet up your attention to this detail or else risk claim denials.

Regional home health intermediary Cahaba GBA reports that the Comprehensive Error Rate Testing (CERT) program has seen an increase in denials owing to issues with the physician signature. Billing the final claim before obtaining physician signature on the POC or giving no indication of when the physician's signature was obtained were identified as the important problems resulting in denials.

According to the Medicare Claims Processing Manual (Publication 100-04), Chapter 10, ?10.1.10.4, a home health claim cannot be submitted until all services have been provided for the episode and the doctor has signed the POC and any subsequent verbal order. That apart, the Medicare Benefit Policy Manual (Publication 100-02), Chapter 7, ?30.2.4 states the POC must be signed and dated by the physician, Cabaha noted in their March newsletter for providers.

The reason why the physician signature issue is bubbling up is likely owing to a combination of factors. Internal communication woes between clinicians and billing staff could be one reason while another could be difficulty in getting hold of the physician's signature.

Bottom line: In these reviews, it's not just reimbursement that is at issue. You could become an objective of fraud scrutiny if the problem is a frequent one. If medical reviewers "identify a pattern of missing... signatures it shall be referred to the appropriate PSC/ZPIC for further development," warns the CMS in March 16 Transmittal No. 327 (CR 6698).

Think about implementing the following tips to head off denials for missing or late physician signatures and the fraud scrutiny that may arise from them.

1. Teach your staff about the particulars of the physician signature requirement and the consequences of non-compliance. Repeat this training many times a year to reinforce information with existing staff and orient new staff.

2. Keep a tab on your charts and claims with a pre-billing audit. Do not send out an end of episode claim before you check for various required items including the physician's signature on the plan of care.

3. Try to work on securing physician signatures. You may require changing your tactics and try faxing orders or working with hospital medical staff to do away with the kinks in the process.

4. Bid goodbye to physicians who are in the habit of not signing orders or signing them too late. This also means bidding good bye to their referrals; but it'll prevent your agency from providing services for which you can't bill.

5. You should be well versed with the signature rule specifics. Stamped signatures will not pass muster in medical review, the CMS says in transmittal No 327 (CR 6698). Do not accept them.

What's more, if you receive an undated signature, see to it that you indicate in the record when you received it, says CMS. Lastly, if a signature is illegible, you may make use of a signature log or attestation statement to verify it - even if those are created after the fact.

Jan Mater-Cavagnero MA, HCS-D, specializes in diagnosis coding for homecarenews.inhealthcare.com home health agencies, as well as the wide variety of issues that impact the hospice industry. Jan is an editor-in-chief for Eli Healthcare, where she has written Home Health elihomecareconnection.com ICD-9 Alert for five years.