Welcome to our final blog post in our series on EMS signature issues. In case you missed them, Part 1 addressed the Authorization of Benefits (AOB) patient signatures, Part 2 discussed the Certificate of Medical Necessity (CMN), formerly known as the PCS, and Part 3 discussed the Advance Beneficiary Notice of Non-Coverage (ABN). In this post we’ll discuss Crew Signatures and Receiving Facility Signatures.
Under Medicare Program Integrity Manual Chapter 3 – 18.104.22.168, Medicare requires that services provided be authenticated by the persons responsible for the care of the beneficiary. In the case of EMS, crew members must sign the PCR. If your crew doesn’t sign the PCR, or the signature fails to meet CMS signature rules, the transport may be denied if it is audited.
In EMS, another reason crew signatures are so important is they are often tied to the crew member’s credential level. In Medicare Benefit Policy Manual Chapter 10 – Ambulance Services, the crew members staffing the ambulance must meet certain requirements and the services provided by the crews may have minimum credential requirements, such as ALS interventions, all of which must be supported by documentation. Therefore, we recommend the signature of all crew members who participated in the transport be obtained and we encourage your service to review your ePCR admin settings to ensure your crew members’ credentials are up to date and listed with their signatures. In their most recent guidance, CGS also suggests obtaining the signature and credentials of all crew members who were on the transport as a best practice. When documenting crew signatures, we have seen instances in the past where one crew member has signed for another. This sort of signature is improper, and we recommend having a policy and procedure in place to ensure crew members sign for themselves on the ePCR. Not only is having all crew members sign the ePCR compliant documentation, but it encourages them to review and take ownership of the documentation of a transport!
To support our focus on this issue, in two recent Palmetto audits the lack of a provider signature or provider credential was a top overpayment reason in multiple states:
Postpayment Service-Specific Probe Results for Ambulance Services (Emergent), Basic Life Support for April through June 2021
Postpayment Service-Specific Probe Results for Ambulance Services (Emergent): Basic Life Support for July through September 2021
While not directly required for payment, the receiving facility signature is also a valuable signature to obtain as a best practice for ambulance documentation. This signature is obtained at the destination when the patient is transferred into the care of another facility or individual.
The facility signature comes up a lot when people talk about abandonment. State laws and local regulations may vary, but here are two good articles that discuss what abandonment is and isn’t:
Facility signatures also serve another purpose covered in Part 1 of this series. When a patient is unable to sign for themselves and an authorized signer is unavailable, a person from the receiving facility may sign along with the ambulance provider in Section III of the AOB form. This signature helps to verify that the transport actually occurred, and the patient was unable to sign.
Signatures in EMS are an underrated issue when it comes to denials. Luckily signature rules are clearer than many other EMS topics, like medical necessity. We hope this serie has helped your service better understand its responsibilities and will lead to better processes for obtaining proper signatures. As always if you have any questions about EMS signatures or EMS compliance, please don’t hesitate to contact us using the form on our website!