PCS — Who Can Sign?
Signature Focus
In our last blog post we visited new rules surrounding repetitive transports and the execution of the Physicians Certification Statement (PCS). This post will primarily focus on how to insure the person signing is correct for the PCS you have obtained.
Requirement…
Remember Medicare requires that a PCS be obtained and maintained on file for every non-emergency, routine transport. The difference between the use of the PCS for repetitives versus non-repetitives lies in when the PCS is obtained (prior to transport for repetitives) and who can sign (physicians must sign repetitives).
Repetitives…
PCS’s for scheduled/repetitive transports can only be signed by a physician. Period!
M.D.’s or D.O.’s are the only health care professionals that can sign a PCS pertaining to a patient who is transported at least three times over a ten-day period or once per week for three consecutive weeks. No other person can sign a PCS for the transport of these patients.
Non-Repetitives…
PCS’s for unscheduled/non-repetitive transports can be signed by the following health care professionals so long as the health care professional has first-hand knowledge of the patient’s overall condition. The person signing the PCS, other than a physician (MD or DO) can be a Registered Nurse (RN), Certified Nurse Specialist (CNS), Physician’s Assistant (PA), Nurse Practitioner (NP) or a “Discharge Planner.” It is important when signing that the health care professional sign his/her name legibly and print his/her certification level as described above.
Discharge Planner Caution!
We often field questions about “Discharge Planners.” One of the common confusions surrounding PCS’s is how to define these persons.
A “Discharge Planner” is someone, typically in the institutional setting, that actually wears that title defining his/her place in the system. For example, while the regulations do not allow for Licensed Practical Nurses (LPN’s) to sign a PCS, it is possible for an LPN that occupies the position of a hospital Discharge Planner to sign the PCS but not in the capacity of the scope of the LPN but rather within his/her role as a titled Discharge Planner. The same scenario would apply to a Social Worker.
Said another way, the LPN floor nurse who does not serve in the specific role as a Discharge Planner would not be acceptable to sign. However the LPN occupying a Discharge Planner job function would be an acceptable signature.
Therefore, “Suzy Smith, LPN, Discharge Planner” would be an acceptable signature for the PCS as long as that person’s title and job function is well defined and there is a proven history of that person occupying a specific “Discharge Planner” role within the facility you are serving for transports, preferably carrying that specific title and job description.
It is important for the ambulance service call-taker or administrator/supervisory staff to properly identify and verify all persons that sign PCS documents on a regular basis so not to mis-identify persons that fall within the regulations surrounding PCS execution.
Method…
The health care professional’s signature must be handwritten, however the rules do allow for an electronic signature that is a computer produced handwritten signature. The acceptable electronic signature would be one where the health care professional signs using an electronic pen on a computer signature pad that generates the signature facsimile onto the PCS, instead of the doctor signing using an ink pen on paper.
An unacceptable signature would be a signature that is an “electronic signature” which would be produced by password and printed on the page in some manner such as “electronically signed.”
Legibility
Recently, the Centers for Medicare and Medicaid Services (CMS) has placed a great deal of emphasis on the legibility of signatures. It is important that even the actual signature be vetted out by EMS personnel as proper or improper.
Signatures must be legible to be accepted. If a signature is illegible (viewing the signature does not yield the identity of the person signing, just by looking at it), then it is important that the name is always printed adjacent to the signature. The best way to cover this is to have the signing health care professional always print his/her name adjacent to any signature, legible or non-legible, and have that person include his/her credentials, as well.
It is always best that the persons signing, sign using his/her full first and last name, however signing using a first initial and last name with the name printed nearby would be acceptable.
Illegibility
CMS rules do allow for what’s called “Signature Attestation” for those health care professionals that habitually sign with illegible signatures. However, this means that a master signature attestation statement or log must be maintained by the ambulance service showing the health care professional names with signatures on the page in order that they can be compared to an actual signature at some later time to prove the identity of the persons signing. This is a lot of work and requires continual record-keeping, not to mention the requirement of keeping such attestation sheets up-to-date to include both incoming and outgoing health care professionals.
We recommend that the request be made of persons signing to sign legibly when possible, but when not possible that the person signing always prints his/her name and credentials on the page.
Signature Dating
Finally, for this discussion it is important that the health care professional signing the PCS always date his/her signature. This is a must! The date that the person signs the PCS should be included adjacent to the signature and that area is separate from the date of service/transport listed at the top of the PCS document, as is the case for the common PCS documents that are widely used in the ambulance industry today.
Who’s Guiding You?
Are you receiving adequate feedback from your billing office concerning the quality of the PCS’s your company is obtaining? If not, you should be.
We continually provide feedback to our clients concerning the proper execution and the quality of the PCS’s they obtain. If you are not regularly reviewing the PCS’s your company is being presented with from the facilities you serve, then you are running the risk of some of those PCS’s being improperly executed.
If you’re not a client and would like to learn more about the way we support our clients in these matters, drop us an e-mail. We’d love to schedule a time to talk with you about the compliance-related services we offer to our clients.
