CMS Addresses Physician Signature Date Requirements

The National Association for Home Care & Hospice (NAHC) requested a policy clarification from CMS regarding signature dating requirements as defined in CR 6698.  Accepted home health practice  has been that if a physician did not date his/her signature, the home health agency could enter the date of receipt on the form. NAHC asked for clarification to confirm that this long accepted practice of dating the physician’s signature would be considered valid in the absence of the physician physically dating the plan of care.

Medical review staff of CMS contractors have also been instructed to accept any log the agency maintains as evidence of date of receipt in instances where the physician signature is not dated nor did agency staff date stamp the actual order.   

CMS’ directive on this subject was that until further instruction is issued, the above procedure is considered appropriate whereby the HHA enters the date of receipt on the form.

The following language regarding plan of care instructions were inadvertently deleted from the online Program Integrity manual about a year ago and not replaced.

27. Attending Physician’s Signature and Date Signed.–The attending physician signs and dates the plan of care/certification prior to you submitting the claim. Rubber signature stamps are not acceptable. The form may be signed by another physician who is authorized by the attending physician to care for his/her patient in his/her absence.

While the regulations specify that documents must be signed, they do not prohibit the transmission of the plan of care or oral order via facsimile machine. You are not required to have the original signature on file. However, you are responsible for obtaining original signatures if an issue surfaces that would require verification of an original signature. If you maintain patient records by computer rather than hard copy, you may use electronic signature. However, all such entries must be appropriately authenticated and dated. Authentication must include signatures, written initials, or computer secure entry by a unique identifier of a primary author who has reviewed and approved the entry. You must have safeguards to prevent unauthorized access to the records and a process for reconstruction of the records upon request from the intermediary, State surveyor, or other authorized personnel or in the event of a system breakdown.

Do not predate the orders for the physician, nor write the date in this field. If the physician left it blank, enter the date you received the signed POC under Item 25. Do not enter “N/A.” Submit an unsigned copy of the HCFA-485. Retain the signed copy.

We hope this clarifies the appropriate policy to follow to ensure compliance.  

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