Complying with Medicare's Signature Requirements
What You Need to Know
Medicare permits both handwritten and electronic signatures. It prohibits rubber signature stamps with narrow exceptions.
- If a healthcare provider's handwritten signature is illegible, you can use a signature log or attestation to validate the identity of the person signing the document.
- Electronic signatures should exist in systems/software products protected against modification. You should also apply appropriate administrative procedures compliant with recognized standards and laws to prevent inappropriate access to or use of electronic signatures.
- You cannot use a rubber signature stamp unless you have a physical disability that prevents you from physically signing documents. You must be able to provide proof to the DME MAC and other Medicare contractors of your inability to sign due to your physical disability.
What this Means for You
Unless you fall under the limited exception for rubber stamp signatures, make sure that all your healthcare providers sign their medical records using either a handwritten signature or an electronic one.
If you need to create a signature log to verify illegible clinician signatures, you should have the typed initials or name next to the individual's handwritten initials or name, ideally with the clinician's credentials included as well. If you choose to submit an attestation statement, you can use the following language:
I, [CLINICIAN FULL NAME], attest that the medical record entry for [DATE OF SERVICE] accurately reflects signatures/notations that I made in my capacity as [INSERT PROVIDER CREDENTIALS] when I treated/diagnosed the above-listed Medicare beneficiary. I attest that this information is true, accurate and complete to the best of my knowledge. I understand that any falsification, omission, or concealment of material fact may subject me to administrative, civil, or criminal liability.
Be aware that if MAC, RAC, SMRC, or CERT reviewers believe that a missing or illegible signature suggests the possibility of fraud, they have the authority to refer you to the appropriate UPIC, Regional Office, and/or State Agency to investigate the matter further.