Does the iPad application’s electronic signature meet CMS regulations?

CMS has published guidance regarding the requirements for validation of the face-to-face visit by a physician when collecting medical record data for risk adjustment. First, the CMS Medicare Managed Care, Chapter 7 (Draft) repeats information that has been published in earlier editions of the Medicare Risk Adjustment Resource Guides:“Qualified physician data for risk adjustment requires a face-to-face visit with the exception of pathology services (professional component only).”

Further, the most recent guidance on signature requirements comes from the 2008 Risk Adjustment Data Technical Assistance, For Medicare Advantage Organizations - RESOURCE GUIDE. Section 10 (d) p.17 outlines the requirements for signatures and credentials needed to validate the face-to-face visit with the beneficiary:

Signatures and Credentials
For purposes of risk adjustment data submission and validation, the MA organizations must ensure that the provider of service for face-to-face encounters is appropriately identified on medical records via their signature and physician specialty credentials. (Examples of acceptable physician signatures are: handwritten signature or initials; signature stamp that complies with state regulations; and electronic
signature with authentication by the respective provider.)

This means that the credentials for the provider of services must be somewhere on the medical record—either next to the provider’s signature or preprinted with the provider’s name on the group practice’s stationery.

If the provider of services is not listed on the stationery, then the credentials must be part of the signature for that provider. In these instances, the coders are able to determine that the beneficiary was evaluated by a
physician or an acceptable physician data source.

(For additional information on acceptable physician data sources, see the above section titled Filtering for Acceptable Provider Types and Physician Data Sources.)

CenseoHealth meets these requirements with its process by using an IPad to complete Health Risk Assessments for each Medicare beneficiary. When the examination is complete, the physician signs the record on the IPad to create the compliant record for Medicare risk adjustment requirements with a
handwritten signature. This tool provides the completed form as a medical record with the actual handwritten signature using ink writing technology.

The use of this process allows for the record containing the actual handwritten signature of the physician to be printed or maintained electronically for future printing or upload to an electronic medical record for use by all users who have access to the electronic medical record.