The Dating Game
This is a game you don’t want to lose, folks. Before you read any further, take a minute and dispose of your date stamp.
In reviewing claims for ZPIC audits, multiple problems with dates have occurred. If the date stamp pre-dates the date that the physician signed his orders it appears to be blatant fraud. Only an idiot would do this, right? Wrongo. We see it so frequently we are appealing to the ICD-10 folks to have date stamp incompetency included as an official disease.
Next, consider the MD who has a date stamp that looks exactly like yours. This results in conflicting dates all over the same document. If I were looking for a reason not to pay a claim, I would have it on the first page of the 485. I could move on to the next claim saving myself a lot of time and effort reading through all the nursing notes. This happens more often than you think. There are three very popular date stamp formats out there. Nobody seems willing to have a date stamp custom made with their name on it.
What if the physician either doesn’t date his signature or does so in a manner that is illegible. Some British educated physicians still use the date format used in most other parts of the world. September 7 would read 7.9 in the UK. When this happens, CMS has given us a very useful tool to verify signatures and dates. It is called a signature attestation form. Please put the following on your letterhead and make a ton of copies. You will need them.
|“I, _____[print full name of the physician/practitioner]___, hereby attest that the medical record entry for _____[date of service]___ accurately reflects signatures/notations that I made in my capacity as _____[insert provider credentials, e.g., M.D.]___ when I treated/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.”|
Notice this form can be used to verify both signatures and dates.
In the past, we have always operated under a rule that was not enforced. We were taught by our fiscal intermediaries and state offices that if a physician did not date his signature, we could simply indicate on the 485 or other order when the document was received in the agency. This is not how the CMS guidelines read and they are now enforcing the rule that the physician must date his signature. The only written exception would be in a hospital or other facility where multiple clinicians were documenting on the same piece of paper and a reasonable assumption could be made as to when the entry was made. This does not happen in home health or hospice.
This is worth repeating:
- Throw away your date stamp
- Ensure that your MD dates his signature
- If not dated, use attestation form.
- Have a signed and dated signature and attestation form in place prior to billing.
I promise that you do not want to lose the dating game.