PalmettoGBA Comments on Comprehensive Error Rate Testing (CERT)
In recent months, Palmetto GBA has seen an escalating number of errors assessed by the Comprehensive Error Rate Testing (CERT) Review Contractor due to signature problems with practitioners’ medical records, x-ray reports and laboratory/radiology orders. The discovery of CERT errors may lead to increased scrutiny of future services billed to Medicare by the individual provider and/or the specialty practice that incurs the errors. To reduce the signature problems, PalmettoGBA plans to provide quarterly updates containing information on unacceptable documentation/signature issues, what is needed to resolve these issues, and suggestions on ways to share this information and improve claims submission/documentation requirements.

Basically, The Centers for Medicare & Medicaid Services (CMS) has long-standing published requirements that a legible, valid signature (identifier) must be present on all substantiating documentation for claims billed to Medicare. Palmetto GBA examined numerous examples of CERT signature denials and found in almost every instance, the basic documentation was acceptable. However, services that were denied due to one of four “not acceptable” signature reasons included:

  • Illegible, unrecognizable handwritten signatures or initials
  • Unsigned “typewritten” progress notes with a typed name only
  • Unverified or unauthorized electronic signatures
  • No indication of the rendering physician/practitioner

PalmettoGBA is sure that this current challenge is fixable and once achieved will prevent the delay in payments caused from claims being denied because documentation is not present to support payment. Important elements to remember:

  • Be sure a handwritten signature is a mark or sign by an individual on a document to signify knowledge, approval acceptance or obligation.
  • Records should clearly indicate they have been “electronically signed by” and include a date/time. We strongly suggest adding verbiage to this effect for clarification and establishing a protocol to ensure valid signatures, are affixed to every order, record, or report within a reasonable time frame, i.e., customarily 48-72 hours after the encounter-but certainly before the claim is submitted to Medicare for payment consideration.