There are a couple of places in HHCoPs where signature and date are referenced, standards for verbal orders and clinical records. A signature and date on orders and the certification are Conditions for Medicare payment.
42 CFR 484.60(b)(4)When services are provided on the basis of a physician or allowed practitioner's verbal orders, a nurse acting in accordance with state licensure requirements, or other qualified practitioner responsible for furnishing or supervising the ordered services, in accordance with state law and the HHA's policies, must document the orders in the patient's clinical record, and sign, date, and time the orders. Verbal orders must be authenticated and dated by the physician or allowed practitioner in accordance with applicable state laws and regulations, as well as the HHA's internal policies.
42 CFR 484.110(b)Standard: Authentication. All entries must be legible, clear, complete, and appropriately authenticated, dated, and timed. Authentication must include a signature and a title (occupation), or a secured computer entry by a unique identifier, of a primary author who has reviewed and approved the entry.
42 CFR 409.43(c)(2)Final percentage payment signature requirements. The plan of care must be signed and dated-
(i) By a physician or allowed practitioner as described who meets the certification and recertification requirements of § 424.22 of this chapter; and
(ii) Before the claim for each episode (for episodes beginning on or before December 31, 2019) or 30-day period (for periods beginning on or after January 1, 2020) is submitted.
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Mary Carr
Vice President, Regulatory Affairs
National Alliance for Care at Home
Washington DC
+1 (202) 547-7424
mkc@allianceforcareathome.org------------------------------
Original Message:
Sent: 01-07-2025 12:16
From: Diana Lecher
Subject: Dating provider signatures when VA is payer source
I understand we need a date on signatures for orders.
I have a VA provider who is ignoring this despite requests and education. VA is the payer source.
I wonder if this rule is for Medicare/Medicaid billing and not a COP for Home Health Agencies.
I appreciate any help anyone can provide.
Diana
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[Meloni] [Jensen] [RN, BSN, MSM]
[Director, Quality Improvement]
[Providence St Joseph Home Care]
[Anaheim] [CA]
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