A Complete Ban on Signature Stamps

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.

In the upcoming November-December Journal, Gloryanne Bryant, RHIA, CCS, recommends that HIM professionals ensure compliance with the ban by participating in documentation checks in areas that have commonly used signature stamps in the past. She suggests that hospitals handle this through teams that include case management, nursing, and HIM. Education on the ban may be needed. Any necessary corrective actions should be taken within a reasonable amount of time, she writes.

Bryant, senior director of corporate coding and HIM compliance at Catholic Healthcare West in San Francisco, notes that signature stamps could become a future target for future Recovery Audit Contractor audits, other investigations, or even the Joint Commission, so “striving for compliance now will pay off in the long run.”



  1. The Centers for Medicare & Medicaid Services recently released the transcripts of the November 2008 Special Open Door Forums on the Medicare recovery audit contractor program. See the Medicare Update weblog’s post at http://tinyurl.com/8cm9xd

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  2. As of January 22, 2009, the U.S. Government Accountability Office indicates that the protests to the contract awards for the permanent Medicare recovery audit contractor program are still not decided. See the Medicare Update weblog’s post at http://tinyurl.com/ak4kmc

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  3. As of February 6, 2009, the U.S. Government Accountability Office on-line docket shows that the bid protests to the permanent Medicare recovery audit contractor program have been “withdrawn.” See the Medicare Update weblog’s post at http://tinyurl.com/bq36eo

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