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CMS Acceptable Electronic Signatures Cheat Sheet by

CMS Signature Requirements, Acceptable Practices
cms     security     digital     healthcare     signature     electrronic     acceptable

Introd­uction: Signat­ure’s Requir­ements

Medicare requires that services provid­ed/­ordered be authen­ticated by the author. The signature for each entry must be legible and should include the practi­tio­ner’s first and last name. For clarif­ication purposes, we recommend you include your applicable creden­tials (e.g., P.A., D.O., or M.D.).

The Centers for Medicare and Medicaid Services (CMS) recently updated the Medicare Program Integrity Manual, Chapter 3, Section 3.4.1.1, include these acceptable electronic signat­ures:

Provider signatures need to meet the criteria during audits and claim reviews. Previo­usly, CMS had clarified that "­ser­vices provid­ed/­ordered be authen­ticated by the author­," either by a handwr­itten or electronic signature. Stamp signatures are not acceptable under any circum­sta­nces. This means some of the old stand-by practices used also need to be updated.

Electronic Signatures

chart "­acc­epted by" with the provider's name,
"­ele­ctr­oni­cally signed by" with the provider's name,
"­ver­ified by" with the provider's name,
"­rev­iewed by" with the provider's name,
"­rel­eased by" with the provider's name,
"­signed before import by" with the provider's name,
digita­lized signature handwr­itten and scanned into the computer,
"this is an electr­oni­cally verified report by John Smith, MD,"
"­aut­hen­ticated by John Smith, MD,"
"­aut­horized by John Smith, MD,"
"­digital signature: John Smith, MD,"
"­con­firmed by" with the provider's name,
"­closed by" with the provider's name,
"­fin­alized by" with the provider's name, and
"­ele­ctr­oni­cally approved by" with the provider's name.
"­Sig­nature Derived from Controlled Access Passwo­rd"

Electronic Medical Records: Recomm­end­ations

The electronic system you select should include a process that verifies the individual signing his/her name has reviewed the contents of the entry and determined it contains what he/she intended.

Safeguards must be in place to protect against unauth­orized access and inappr­opriate use of your electronic signat­ures, by whatever method, by anyone other than the designated individual to whom it is assigned. It is to be unique to the indivi­dual, and not reassigned nor reused by someone else. Furthe­rmore, measures should be in place to protect the 'links' between electronic health inform­ation and signatures which prevent unapproved alteration through removal, copying or transfer.
 

CMS

The Medicare Program Integrity Manual, Chapter 3, explains Medicare’s signature requir­ements:
Electronic signat­ures usually contain date and timestamps and include printed statements (e.g., 'elect­ron­ically signed by' or 'verif­ied­/re­viewed by') followed by the practi­tio­ner’s name and preferably a profes­sional design­ation. Note that the respon­sib­ility and authorship related to the signature should be clearly defined in the record.
Digital signat­ures are an electronic method of a written signature that is typically generated by special encrypted software that allows for sole usage

Note: Be aware that electronic and digital signatures are not the same as 'auto-­aut­hen­tic­ation' or 'auto-­sig­nature' systems, some of which do not mandate or permit the provider to review an entry before signing. Indica­tions that a document has been 'Signed but not read' are not accept­able.

CMS: Electronic Signatures

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

The individual whose name is on the alternate signature method and the provider bear the respon­sib­ility for the authen­ticity of the inform­ation for which an attest­ation has been provided. Physicians are encouraged to check with their attorneys and malpra­ctice insurers concerning the use of altern­ative signature methods.

CMS: Electronic Prescr­ibing

Electronic prescr­ibing (e-pre­scr­ibing) is the transm­ission of prescr­iption or prescr­ipt­ion­-re­lated inform­ation through electronic media. E-pres­cribing takes place between a prescriber and dispenser, pharmacy benefit manager (PBM), or health plan. It can take place directly or through an e-pres­cribing network. With e-pres­cri­bing, health care profes­sionals can electr­oni­cally transmit both new prescr­iptions and responses to renewal requests to a pharmacy without having to write or fax the prescr­iption. E-pres­cribing can save time, enhance office and pharmacy produc­tivity, and improve benefi­ciary safety and quality of care.
A “quali­fied” e-pres­cribing system is one that meets the Medicare Part D requir­ements described in 42 CFR 423.160 (Standards for Electronic Prescr­ibing).

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