CMS Signature Requirements

CMS published  specific requirements associated with authenticating orders for tests. To encourage and implement best practice for our orders, we will be utilizing these guidelines for all payors. In confirming its position, CMS specifically states:

“For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a handwritten or an electronic signature. Stamp signatures are not acceptable.”

CMS also requires that orders presented from the treating physician or non-physician practitioner (NPP) be signed (either handwritten or electronic) by that treating physician or NPP. This pertains to radiology exams paid by the physician fee schedule or the Outpatient Prospective Payment System that require a physician to provide the diagnostic reading. The CMS updated policy regarding test orders reads:

“a written order for diagnostic tests…(for example, that are paid under the Physician Fee Schedule (PFS) or under the Outpatient Prospective Payment System (OPPS), such as  X-rays, MRIs, … must be signed by the ordering physician or NPP.”

Acceptable forms of signature include:
• Legible handwritten signature
• Illegible handwritten signature, but only if the illegible signature can be confirmed on the order
          a) Typed or printed name underneath the illegible signature or initials
          b) Prescription pad with providers listed and the specific ordering provider circled
• Electronic or digitized signature containing a printed validation statement and date and time stamp
          a)“Electronically signed by (physician/NPP) on (date) at (time)”

This information is being presented to you for your convenience. Orders that are not authenticated by the author in one of the acceptable formats listed above will be deemed non-reimbursable. CMS auditors, such as CERT, RAC, Carrier, and MAC auditors, will be ensuring we adhere to the above guidelines in their audits. You may obtain more information on CMS’s position by accessing the following documents online:

CMS Guidelines 1
CMS Guidelines 2


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