The CMS CERT program -- Comprehensive Error Rate Testing Program ... a CMS post payment audit/review program that does audit anesthesia CRNA or MD claims made this recent clarification on signatures and credentials. If names are not legible and/or credentials are missing... the claim will be denied. An electronic signature on anesthesia record is not a norm as of yet, and we all know how difficult they can be to read, especially to an outsider -an auditor- remind your staff/employees/fellow CRNAs... CRNAs are subject to CERT -I have sections in my lectures about CERT- and the documents had better be legible or the payment could be denied and pulled back. Just yesterday we lost an appeal due to a missing credential on the documentation. Here is the link to the Cigna CMS site discussing it with the actual text below. Although the text below discusses specifically ordered lab and diagnostic testing, the CERT rules apply across the board, hence our recent denial for missing credentials on an anesthesia record. We are seeing CERT auditing requirements appear within non governmental payers as well, BX carriers for example; hence the importance of providing a complete and legible provider signature on all appropriate documentation. This is of even greater necessity in those practices that deliver anesthesia services in the medically directed practice environment. In this practice environment a clearly documented CRNA service may in fact be the difference between the CRNA or their employer being reimbursed or another provider, namely an MD anesthesiologist- being reimbursed.

In following up on this article with Cigna / CMS / CERT directly, this is the comments from the auditor we spoke directly with:

".....the CERT Review Process is now strictly enforcing a rule that there must be a legible signature on all clinic notes, orders and other documentation used to substantiate a claim billed to Medicare. Failure to have a written or electronic signature will result in a denied claim even if medically necessary."

http://www.cignagovernmentservices.com/partb/pubs/mb/2009/08_09/index.html

Physician Signature Clarification

During reviews performed by the Comprehensive Error Rate Testing ( CERT ) contractor, concerns have emerged involving the requirements for physician signatures on orders for diagnostic tests. The following information is intended to clarify the requirements for providers.

IOM Pub 100-2, Ch 15, sect 80.6 et sub. concerning physician's signatures reads (in part) as follows:

An order may be delivered via the following forms of communication:

A written document signed by the treating physician/practitioner, which is hand-delivered, mailed, or faxed to the testing facility; NOTE: No signature is required on orders for clinical diagnostic tests paid on the basis of the clinical laboratory fee schedule, the physician fee schedule, or for physician pathology services . . .

If the order is communicated via telephone, both the treating physician/practitioner or his/her office, and the testing facility must document the telephone call in their respective copies of the beneficiary's medical records. While a physician order is not required to be signed, the physician must clearly document, in the medical record, his or her intent that the test be performed.

Keep in mind that while the lab request itself does not require a signature, there must be a signature in at least one of two places – either on the office note in which the intent to order the test was clearly documented, or on the requisition or lab order slip.

Remember, providers have the same appeal rights for CERT initiated denials as they do for denials initiated through CIGNA Government Services. All of the same Medicare guidelines apply, including those regarding the 120-day time frame allowed for an appeal (redetermination).

The Redetermination (Appeal) Request Form can be found at: http://www.cignagovernmentservices.com/partb/forms/gateways/redetermination.html