Re: Medicare Record Signatures for Nurse Practitioners and the Supe...

According to the billing guidelines a supervising provider does not have to
sign the record. Your state may have credentialling/supervision
guidelines or policies that require a signature on NP services but it has NEVER been
a requirement for billing purposes. Sounds like your CMS contractor is the
one with the problem. Ask them to show you where in their regulations the
supervising provider has to sign the note for incident to billing.





In a message dated 5/10/2016 2:27:26 P.M. Central Daylight Time,
bsmith@conradpearson.com writes:


We are getting prepayment audits and then denials once we send the medical
record. Our NP has electronically signed the EHR and we have performed
billing under the supervising MD’s NPI (incident to billing and direct
supervision). Our CMS contractor has denied payment because the supervising
MD did not co-sign the medical record. The supervising MD is the MD on the
hallway with the NP at the time of the patient visit (so physically in the
building). Before I go to our Executive Committee with “this problem”,
I need more ammunition than the Medicare Manual 3.3.2.4 – Signature
Requirements and the CMS Signature Requirements – we do have a Signature Log and
are using electronic signatures.
Do any of you have advice as to how to you handle the EHR - Incident to -
NP and MD Signatures - Medicare compliance??
Becky Smith, CPC, ASC-UR
Director of Administrative Operations
1325 Wolf Park Drive, Suite 103
Germantown, TN 38138
(901) 252-3401 (o)
(901) 763-4305 (f)
(901) 734-1063 (c)
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Comments

  • I sent this to Becky.

    I found some articles for you.

    Here is the one where you have the problem. See middle of page 2!

    https://www.cahabagba.com/documents/2013/04/q-and-a-cgba-signature-requirements.pdf

    "A supervising physician counter signature is required after a nurse practitioner documentation/signature that work incident to a supervising physician. Refer to incident to guidelines in the Medicare Benefit Policy Manual - Chapter 15; section 60 - Incident To: http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/bp102c15.pdf"

    Your EHR company should set up a flag/warning for you about this!



    Other states differ. This is Palmetto GBA's policy. It's different than Cahaba's!

    http://www.palmettogba.com/palmetto/providers.nsf/DocsCatHome/JM Part B

    In the chart towards the bottom for "incident to" it says the chart must be signed by the NPP or supervising physician

    So, bottom line, it varies by carrier and state-to-state potentially.

    Check your rules!

    Karl Ellzey
  • --part1_233251.51d5647.44664958_boundary
    Content-Type: text/plain; charset="US-ASCII"
    Content-Transfer-Encoding: 7bit

    It appears as though Cahaba is applying more stringent guidelines than
    required by National CMS. I do not see anything in the CMS manual referred to
    below that requires the supervising provider's signature. I would fight
    this tooth and nail through the regional CMS office and national CMS if I had
    to.


    In a message dated 5/12/2016 2:29:38 P.M. Central Daylight Time,
    karl@my914-6.com writes:

    I sent this to Becky.

    I found some articles for you.

    Here is the one where you have the problem. See middle of page 2!

    https://www.cahabagba.com/documents/2013/04/q-and-a-cgba-signature-requireme
    nts.pdf

    "A supervising physician counter signature is required after a nurse
    practitioner documentation/signature that work incident to a supervising
    physician. Refer to incident to guidelines in the Medicare Benefit Policy Manual -
    Chapter 15; section 60 - Incident To:
    http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/bp102c15.pdf"

    Your EHR company should set up a flag/warning for you about this!



    Other states differ. This is Palmetto GBA's policy. It's different than
    Cahaba's!

    http://www.palmettogba.com/palmetto/providers.nsf/DocsCatHome/JM Part B

    In the chart towards the bottom for "incident to" it says the chart must
    be signed by the NPP or supervising physician

    So, bottom line, it varies by carrier and state-to-state potentially.

    Check your rules!

    Karl Ellzey


    --part1_233251.51d5647.44664958_boundary
    Content-Type: text/html; charset="US-ASCII"
    Content-Transfer-Encoding: quoted-printable






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    So, bottom line, it va=
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    Karl Ellzey

    --part1_233251.51d5647.44664958_boundary--
  • I agree with Jan. There may have, a long time ago, been something in CMS Pub 100-02 about a counter signature being required, but not for many years. The link Cahaba provides for the CMS verbiage doesn't even work. I'd fight this too.

    Kris

    Kris Cuddy, CPC, CIMC
    Healthcare Compliance Analyst
    Compliance Office
    Michigan State University HealthTeam
    East Lansing, MI
    Ofc: 517-355-4547
    Fax: 517-353-5292

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