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Top Provider Questions – Comprehensive Error Rate Testing (CERT) Program

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What are acceptable electronic signature notations?
- All patient medical record entries must be legible, complete, dated, and authenticated in written or electronic form by the person responsible for providing or evaluating the service provided.
  
  Electronic signatures should contain a date and timestamp, printed statement (see below), followed by the practitioner's name, and preferably a professional designation.
  
  Examples of acceptable electronic signatures include but aren't limited to:
  - Chart 'Accepted By' with provider's name, designation
  - 'Electronically signed by' with provider's name, designation
  - 'Verified by' with provider's name, designation
  - 'Reviewed by' with provider's name, designation
  - 'Released by' with provider's name, designation
  - 'Signed by' with provider's name, designation
  - 'Signed before import by' with provider's name, designation
  - 'Signed: John Smith, M.D.' with provider's name, designation
  - 'This is an electronically verified report by John Smith, M.D.'
  - 'Authenticated by John Smith, M.D.'
  - 'Authorized by: John Smith, M.D.'
  - 'Digital Signature: John Smith, M.D.'
  - 'Confirmed by' with provider's name, designation
  - 'Closed by' with provider's name, designation
  - 'Finalized by' with provider's name, designation
  - Digitalized signature: Handwritten and scanned into the computer. Note: Electronic and digital signatures aren't the same as 'auto-authentication' or 'auto-signature' systems, some of which don't mandate or permit the provider to review an entry before signing.
  Indications that a document is 'Signed but not read' aren't acceptable
  
  Reviewed 04.27.2026
What is CERT?
- CMS implemented the Comprehensive Error Rate Testing (CERT) program to measure improper payments in the Medicare Fee-for-Service (FFS) program. CERT is designed to comply with the Improper Payments Information Act (IPIA) of 2002, as amended by the Improper Payments Elimination and Recovery Improvement Act (IPERIA) of 2012.
  
  Reviewed 04.27.2026
How does the CERT process work?
- - CERT selects a stratified random sample of claims submitted to Part A/B Medicare Administrative Contractors (MACs) during each reporting period.
  - CERT requests supporting documentation from the provider or supplier who submitted the claim for payment.
  - An independent medical review contractor reviews the documentation to determine if the claim paid according to Medicare coverage, coding and billing rules.
  - If the documentation doesn't support that the criteria are met, or the provider fails to submit medical records to support the claim billed, the claim is counted as a total or partial improper payment.
  - CERT notifies the MAC who processed the claim if an improper payment is identified.
  - The MAC adjusts the claim to recoup (for overpayments) or reimburse (for underpayments) the provider's payment.
  - CMS calculates the annual Medicare FFS improper payment rate published in the Health and Human Services (HHS) Agency Financial Report (AFR).
  See the CMS CERT webpage for additional information.
  
  Reviewed 04.27.2026
How do providers know when CERT selects a claim for review?
- When a claim is selected for review, CERT sends the provider an Additional Documentation Request (ADR) letter that includes:
  - Identifying information for the selected claim.
  - A list of documentation requested for the service or procedure under review.
  - Timeframe and instructions for submitting medical records.
  - A barcoded coversheet to use as page 1 of your response.
  Reviewed 04.27.2026
Where does CERT send ADR letters?
- For each sampled claim/individual CID, CERT sends:
  - The FIRST ADR letter to the billing provider's address on file in PECOS.
  - SUBSEQUENT ADR letters to an alternate address if you call CERT Customer Service (888.779.7477) to provide one.
  See Letters and Contact Information.
  
  Chain Address Program
  Providers with at least 10 PTAN numbers who want to elect a single point of contact (POC) can participate in the "chain address" program:
  - Call the CERT office (888.779.7477) or email the CGS CERT Coordinator (J15CERTCID@cgsadmin.com).
  - Provide a list of PTAN numbers and the designated POC information.
  - To assure you supply the information to CERT within the 45 day timeframe, CERT will email or call the POC with a list of outstanding CID numbers.
    - NOTE: Since the FIRST letter is sent to the provider address on file, the list may include requests the POC has not yet received.
    - When requested, the CERT CSR will forward a copy of the letters not yet received.
  Group Calls
  To reduce provider burden, when multiple calls are due to the same phone number, the CERT RC groups the calls so that a single contact is made with the provider (providers) associated with that phone number to discuss all outstanding requests.
  
  IMPORTANT NOTE: This change is ONLY in regards to the CERT program.
  
  Reviewed 04.27.2026
What should we do if our claim is selected for a CERT review?
- - Review the barcoded coversheet for specific documentation requested.
  - Keep a copy of the CERT letter, including the barcoded coversheet, on file within your agency.
  - Gather all documentation requested and any additional documentation that supports the coverage and medical necessity of all services billed for the dates of service indicated on the request.
  - Photocopy each record. Make sure all copies are complete, legible, and contain both sides of each page.
  - Place the barcoded coversheet in front of the documentation.
  - Send your documentation to the CERT Documentation Center. Acceptable submission methods are listed in the ADR letter and Submit Records to CERT.
  Reviewed 04.27.2026
How long do we have to send the requested documentation?
- Please see the initial and subsequent request schedules under Letters and Contact Information.
  
  Reviewed 04.27.2026
How can we ensure our documentation is received timely?
- - Designate a CERT point of contact for your agency who's responsible for receiving the requests and ensuring responses are submitted timely.
  - Post a sample copy of the ADR letter and routing instructions where requests are delivered (i.e., billing provider address in PECOS).
  - Train staff responsible for answering the telephone on the CERT process and routing instructions.
  - Make sure your main provider address and telephone number in PECOS are correct.
  - If you have questions about the request, please call the CERT Documentation Center (888.779.7477).
  Reviewed 04.27.2026
Do we need the beneficiary's authorization to release information to the CERT contractor?
- No, when enrolling in Medicare, beneficiaries sign a release authorizing Medicare to obtain their medical records at any time. Providing medical record documentation to the CERT contractor doesn't violate the Health Insurance Portability and Accountability Act (HIPAA).
  
  Reviewed 04.27.2026
Do we need to obtain documentation from other providers?
- Yes, the billing provider is responsible for obtaining and providing all requested medical record documentation related to the services billed. This includes medical records that reside with a third party (e.g. clinics, labs, hospitals, physicians).
  
  Reviewed 04.27.2026
How are CERT errors assigned?
- If CERT identifies an improper payment, the error is assigned to the provider who billed the services and the MAC who processed the claim.
  
  Reviewed 04.27.2026
What outcomes are expected from the program?
- CERT error rates help CGS identify services with the greatest risk to the Medicare Trust Fund and direct educational activities to reduce improper payments.
  
  Reviewed 04.27.2026
What if we find additional documentation that we didn't send with our original response?
- You may send additional documentation to the CERT Documentation Center (CDC) at any time, even after the requested time frame. Be sure to include a copy of the bar-coded cover sheet to identify the claim identification (CID) number associated with your documentation.
  
  Reviewed 04.27.2026
Why did the CERT contractor consider my claim an error?
- CERT Assignment of Error Categories explains when a claim is placed in one of the 5 major error categories. Tips on how to avoid these errors are listed below.
  - No Documentation
    - Submit supporting documentation for the service(s) billed within the timeframe indicated on the request. See Avoid CERT No Documentation Errors for additional information.
  - Insufficient Documentation
    - Review the barcoded coversheet for a list of documents typically needed to support Medicare payment. The provider that billed the claim is responsible for maintaining and submitting all documentation necessary to support the services billed. In some cases, you may need to obtain records from a different provider (e.g., referring/ordering provider or rendering provider/facility) and/or for dates prior to and/or after the billed date of service.
  - Medical Necessity
    - Ensure the documentation you submit clearly illustrates compliance with all applicable Medicare statutes and regulations, billing instructions, National Coverage Determination (NCDs), Local Coverage Determinations (LCDs), and provisions in the CMS Internet-Only Manuals (IOMs).
  - Incorrect Coding
    - Ensure the documentation you submit supports the codes reported on the claim (e.g., procedure and diagnosis codes correspond with AMA/ADA/NUBC coding guidelines; HIPPS codes correspond with patient assessments; patient discharge status codes correspond with the patient's location/care received after discharge/transfer).
  - Other
    - Ensure the documentation you submit, including a signature, is legible. If necessary, include a signature log or attestation.
  Reviewed 04.27.2026
What happens if our claim receives an error?
- - CGS will adjust the claim to recoup an overpayment or reimburse an underpayment.
  - The CGS CERT Coordinator will fax a detailed letter to the billing provider's fax number on file with the CERT office.
  - You can identify claim adjustments on your remittance advice or by using the myCGS portal or Direct Data Entry (DDE) system (Part A & HHH providers).
  Reviewed 04.27.2026
What is a CERT additional documentation request?
- A CERT medical review specialist may issue a new additional documentation request (Tech Stop) to obtain a specific item of missing documentation necessary to complete the review. The response timeframe for such a request follows the Subsequent Request Schedule:
  - Day 1: Send letter 1.
  - Day 1: Telephone contact to follow up on request and offer assistance.
  - Day 10: Send letter 2.
  - Day 10: Telephone contact to follow up on request and offer assistance.
  - Day 16: Claim back in review process.
  Reviewed 04.27.2026
Where can I get more information about the CERT program?
- For additional information about the CERT program, please visit:
  - CERT C3HUB
  - Comprehensive Error Rate Testing | CMS
  Reviewed 04.27.2026
Can a CERT error result in a Unified Program Integrity Contractor (UPIC) referral?
- No, the CERT contractor doesn't make UPIC referrals. The CERT program identifies and measures improper payments rather than fraud, waste or abuse.
  
  Reviewed 04.27.2026
What causes a CERT error?
- Most CERT errors are a result of the provider's failure to submit sufficient documentation to support medical necessity for the services billed rather than an indication that the services aren't medically necessary. Please review the details of each request and submit all documentation within the required timeframe.
  
  Reviewed 04.27.2026
How do I avoid SNF certification errors?
- Please review SNF Certification Requirements.
  
  Reviewed 04.27.2026
What are the requirements for IRF claims?
- Please review IRF Errors & Documentation Requirements.
  
  Reviewed 04.27.2026
Where can I find help with the Two-Midnight rule?
- Please review The Two-Midnight Rule: Preventing Denials.
  
  Reviewed 04.27.2026
Why am I getting incorrect Discharge Status errors?
- Please review CERT Error: Patient Discharge Status Codes.
  
  Reviewed 04.27.2026
How can my lab avoid errors?
- Use the Lab Services/Orders Documentation Review Decision Tree for help with proper documents to have on file.
  
  Reviewed 04.27.2026
When billing for Prolonged Services, are we required to document time?
- "The total time on the date of the encounter spent caring for the patient should be documented in the medical record when it is used as the basis for code selection."
  
  References:
  Reviewed 04.27.2026

License for Use of "Physicians' Current Procedural Terminology", (CPT) Fourth Edition

AMA Disclaimer of Warranties and Liabilities.

CMS Disclaimer

POINT AND CLICK LICENSE FOR USE OF "CURRENT DENTAL TERMINOLOGY", ("CDT")

Top Provider Questions – Comprehensive Error Rate Testing (CERT) Program

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