Signatures

In these situations, the services are not billable to Medicare. Palmetto GBA will not consider attestation statements from someone other than the author of the medical record entry in question. This is even in cases where two individuals are in the same group. One may not sign for the other in medical record entries or attestation statements.

Last Reviewed: 9/21/2023

A provider signature attestation attests that a medical record entry accurately reflects signatures/notations a provider made when treating/diagnosing a Medicare beneficiary.

Last Reviewed: 9/21/2023

An attestation statement can be included with your medical record documentation to authenticate the author of a medical record when the author’s signature is illegible or missing. In order to be considered valid for Medicare medical review purposes, an attestation statement must be signed and dated by the author of the medical record entry and must contain sufficient information to identify the beneficiary.

Attestation statements are not acceptable for unsigned physician orders/requisitions. If an order for a test is unsigned, you may submit progress notes showing intent to order the tests. The progress notes must specify what tests you ordered. A note stating “ordering lab” is not sufficient.

Last Reviewed: 9/21/2023

No, reviewers cannot consider attestation statements from someone other than the author of the medical record in question. Even in cases in which two individuals are in the same group, one may not sign for the other in medical record entries or attestation statements.

Last Reviewed: 9/21/2023

If you need an attestation for an illegible signature, you can download a sample of an attestation statement on the CERT contractor website or you can use the following statement:

“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.”

While the format of the statement is acceptable, CMS does not require or instruct providers to use a certain form or format.

Last Reviewed: 9/21/2023

Yes, reviewers will consider all valid attestations regardless of the date they were created except in those cases where the regulations or policy indicate that a signature must be in place prior to a given event or a given date.

Signature Attestation Resources

• IOM 100-08 Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4.C (PDF)
• CMS MLN "Complying with Medicare Signature Requirements" Fact Sheet 
• CMS MLN "Complying with Documentation Requirements for Laboratory Services" Fact Sheet 

Last Reviewed: 9/21/2023

A signature log is a typed or printed listing of a provider’s name with his/her corresponding handwritten signature and initials. A log can be for a single individual or for a group. In the case of an ambulance provider, a signature log could list the typed or printed names of the ambulance crew members with their corresponding handwritten signatures and initials. Medicare encourages providers to include their credentials on the signature log.

Last Reviewed: 9/21/2023

A signature log can be submitted with your medical record documentation to identify the author associated with initials or an illegible signature in the record. 

Last Reviewed: 9/21/2023

Yes, a signature log can be created at any time. Reviewers will consider all signature logs regardless of the date they were created.

Signature Log Resources

• IOM 100-08 Medicare Program Integrity Manual, Chapter 3, Section 3.3.2.4.B (PDF)
• CMS MLN "Complying with Medicare Signature Requirements" Fact Sheet

Last Reviewed: 9/21/2023