The clarifications continue over CMS’s approach to signature stamps. This past July CMS issued a clarification that stamps were not permissable on any medical record. Now a new clarification advises that some payers do not accept stamps but the Conditions of Participation do not prohibit them.

In the latest memorandum, dated October 24, CMS writes that the Conditions of Participation:

“do not prohibit the use of rubber stamps in a hospital setting, when properly controlled, for authentication of medical record entries. However, as a point of information for surveyors and providers, we are taking this opportunity to add an information-only statement to the interpretive guidance for §482.24(c)(1) to note that some payers, including Medicare, may not accept such stamps as sufficient documentation to support a claim for payment.”

The Federal Trade Commission has pushed back the compliance deadline for its identity theft “red flag” rules. The original deadline was less than two weeks away. The new deadline is May 1, 2009.

The red flag rules require businesses that extend credit to their customers to develop and implement written identity theft prevention programs. Healthcare organizations fall under the rule, say attorneys. (more…)

UPDATE: CMS has since released new clarification stating that stamps are not prohibited under the Conditions of Participation, but that some payers may not accept them.

The Centers for Medicare and Medicaid Services no longer accepts signature stamps on any record. CMS attempted to clarify the scope of the ban this summer, but the message may not have percolated to all corners of the industry yet.

In July CMS stated that “stamped signatures are not acceptable on any medical record.” The prohibition applies to all providers and suppliers. Medicare will only accept “handwritten, electronic signatures or facsimiles of original written or electronic signatures.”

In spring CMS published a ban on signature stamps focused narrowly on the certification of terminal illness for hospice. The subsequent July notice explicitly included all medical records. (more…)

In a June print story on bad documentation practices in electronic health records, Stephen Levinson, MD, warns against poorly designed systems that encourage busy physicians to copy old information forward with a single click, speeding them past performing and documenting care.

Copying forward a previous review of systems without reviewing changes in the patient’s status, for example, is noncompliant and potentially fraudulent, Levinson says. Above all, it is poor care. “The tool has taken away what the doctor is supposed to do, which is to obtain information on the review of systems since the last visit,” he says.

Is there ever an appropriate use of copy forward?

Levinson says yes, with an important caveat. (more…)

The Centers for Medicare and Medicaid (CMS) has reported on the status of the recovery audit contractor (RAC) program in Medicare for fiscal year 2007. In the report, CMS highlights improvements that will be made as it implements the permanent RAC program by 2010. (more…)