The CMS 1997 documentation guidelines for E/M services do not specifically state a requirement for a provider signature. However, more recent documents clearly indicate the need for a “signature.” While the 1997 document states the requirement as “legible identity” of the provider, the Medicare Program Integrity Manual now states: “For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a hand written or an electronic signature. Stamp signatures are not acceptable.” The manual gives examples of what is or is not acceptable.

Acceptable
1. Legible full signature.
2. Legible first initial and last name.
3. Illegible signature over a typedor printed name.
4. Illegible signature where theletterhead, addressograph, or other information on the page indicates the identity of the signator.
5. Illegible signature but documentation submitted for audit is accompanied by a signature log or an attestation statement.
6. Initials over a typed or printed name.
7. Initials accompanied by a signature log or attestation statement.
8. Unsigned handwritten note where other entries on the same page in the same handwriting are signed.

Not Acceptable
1. Initials or illegible signature not over a typed or printed name, not on letterhead, and not accompanied by a signature log or attestation statement.
2. Unsigned typed note with or without provider's name typed.
3. Unsigned handwritten note, the only entry on the page.
4. “Signature on file.”

Additional Considerations
An example of an attestation statement is given: “I (full name), hereby attest that the medical record entry for (date of service) accurately reflects signatures/ notations that I made in my capacity as (credentials, e.g. MD) when I treated or diagnosed the above listed Medicare beneficiary. I do hereby attest that this information is true, accurate, and complete to the best of my knowledge and I understand that any falsification, omission, or concealment of material fact may subject me to administrative, civil, or criminal liability.”

For electronic signatures, CMS states that providers using electronic systems need to recognize that there is potential for misuse or abuse with alternate signature methods. Providers need a system and software products that are protected against modification and should apply administrative procedures that are adequate and correspond to recognized standards and laws.

One can easily see that, for paper records, a signature file is the easiest way to go. A sample signature file form to use for all of the signatures in your practice is available online with this article at PracticalDermatology.com. You can download copies or reproduce your own office log sheet. Should you ever be asked for records for audit, attach a copy of the form.

Initials/Signature Log