August 19, 2025
CERT Signature Errors on the Rise
J15 is seeing an increase in Comprehensive Error Rate Testing (CERT) denials related to signature issues (i.e., signatures that are missing, illegible, or not dated).
Signature Requirements
Services provided or ordered for Medicare patients must be authenticated by the author with some form of signature. This includes orders and medical record documentation for all services provided. The signature for each entry must be legible and include the individual's credentials and date.
The purpose of a rendering, treating, or ordering practitioner's signature in a patient's medical records, operative reports, orders, test findings, etc., is to demonstrate that services submitted to Medicare are accurately and fully documented, reviewed, and authenticated. It confirms the provider certifies the medical necessity and reasonableness for the service(s) submitted to the Medicare program for payment consideration.
Acceptable Signatures
Methods of signing records, test orders, and findings include:
- Handwritten
- Electronic
- Electronic signatures usually include date and timestamps and 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 record should clearly define the responsibility and authorship related to the signature.
- Digital signatures are an electronic method of a written signature that is typically generated by special encrypted software that allows for sole usage.
Electronic and digital signatures are not the same as "auto-authentication" or "auto-signature" systems. An indication that a document is "Signed but not read" isn't acceptable.
Signature Stamps
Stamped signatures are generally not acceptable. In accordance with the Rehabilitation Act of 1973, CMS permits use of a rubber stamp for signature in cases where an author with a physical disability can provide proof to a CMS contractor of his or her inability to sign their signature due to their disability.
By affixing the rubber stamp, the provider is certifying that they reviewed the document.
Signature Log
If a signature is illegible, evidence in a signature log or attestation statement is considered. Providers may submit a signature log that lists the typed or printed name of the author associated with initials or illegible signatures. You may include the signature log on the actual page where the initials or illegible signature is used or as a separate document. The signature log should also include the individual's credentials.
Attestation Statements
If an order is missing a signature, a claim reviewer must disregard the order. However, if any other medical record documentation is missing a signature, a signature attestation from the medical record entry author is acceptable.
The attestation statement must contain the medical record entry author's signature, date, and sufficient information to identify the beneficiary. Attestation statements aren't accepted when there's no associated medical record entry. An example of an acceptable attestation statement is available in CMS Medicare Program Integrity Manual (Pub. 100-08), Chapter 3, section 3.3.2.4
.
Attestation statements from someone other than the medical record entry author in question aren't acceptable. Two individuals in the same group may not sign for the other in medical record entries or attestation statements.
An attestation after the date of service is acceptable in most cases.
Exception: Specific signature requirements (e.g., a plan of care requires a signature before rendering services) outlined in a relevant regulation (i.e., national coverage determination (NCD), local coverage determination (LCD), or CMS manual) takes precedence.
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