Most physicians would prefer to avoid being targeted in the cross hairs of a Medicare auditor. The key to doing so, according to Cynthia Hughes, C.P.C., an AAFP coding specialist, is to understand and follow CMS' recently updated signature guidelines, which are outlined in the March 16(www.cms.gov) MLN Matters.
"Physicians need to make sure everything is signed and legible and will support the service that was rendered to the patient," said Hughes. That's the best way to avoid claims denials and attempted recovery of previously paid benefits by CMS auditors, she added.
Hughes and other staff members of AAFP's Practice Support Division recently created new content for the coding resources area of the Academy's website in response to CMS' new guidelines. The information there spells out CMS directives on such issues as
- handwritten signatures and acceptable signature formats,
- valid electronic signatures,
- attestation statements on unsigned documentation, and
- signature logs.
Physicians must understand that the clinician's signature serves as authentication of services rendered or ordered, said Hughes. Furthermore, CMS will not accept signature stamps for Medicare or Medicaid claims.
Physicians also will want to pay close attention to the CMS guidelines because the agency has created a small army of auditors to review Medicare claims, said Hughes.
Those auditors include recovery audit contractors, or RACs; zone program integrity contractors; program safeguard contractors; and comprehensive error rate testing contractors, according to the article in MLN Matters.
All of the above entities are responsible for "measuring, detecting and correcting improper payments, as well as identifying potential fraud in the fee-for-service Medicare program," said the article.
What physicians may not know is that the auditors share information, said Hughes. If physicians are not following all the prescribed rules -- for example, if patient records are going unsigned or physicians scribble an illegible signature -- then physicians could end up under the microscope of more than one of the audit contractor groups, she said.
Furthermore, said Hughes, issues that are under review -- as well as the percentage of errors found -- are published by Medicare administrative contractors and may be the basis for further review by an RAC or even a Medicaid integrity contractor.
In addition, Hughes said, other staff members in the medical practice need to stay current on CMS regulations, too. It's critical that physicians train all staff members who respond to a CMS contractor's requests for records, she said. Staff members must learn to thoroughly review all paperwork, including signature lines, before any documents are released to CMS auditors for scrutiny.