CMS Clarifies Signature Requirements

October 27, 2017
Rick Gawenda

The Centers for Medicare and Medicaid Services (CMS) has issued revised instructions related to signature requirements to clarify that the responsible party has accepted responsibility for the care of the beneficiary and authenticated related documentation. CMS discusses illegible signatures, signatures missing from documentation, signature log, and signature attestation statement.

In the revised instructions, the CMS provides examples of when the signature requirements are met and when the MACs, CERT and ZPICs/UPICs should contact the billing provider. Lastly, the revised instructions discuss electronic signatures and signature dating requirements.

To access the revised instructions, click

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  1. In our last hospital joint commission review in our Outpatient therapy department we were told that the MD signatures must be timed as well as dated. This only becomes a problem with therapy plans of cares, and non-electronic scripts I did not see reference to timing physician signatures. Is this a MC requirement and if so how should we handle physicians who do not time their notes with prompting and multiple requests. Thank you.