Importance of Proper Signatures
for CMS Data Validation

Each year, the Centers for Medicare & Medicaid Services (CMS) randomly selects Medicare Advantage (MA) organizations to participate in the data validation process. Humana has participated for several years, and will be part of the data validation process again this year.

The data validation serves to facilitate the accuracy and integrity of the MA payment system. Specifically, the process seeks to verify the following:

• Medical record documentation supports the assigned Hierarchical Condition Category (HCC) code.
  
• All dates of service are signed and dated by a physician or an appropriate physician extender (e.g. a nurse practitioner).

Past data validation results show room for improvement in these areas, particularly in the area of physician signatures.

Please remember the following:

• All dates of service that are identified for review must be signed and dated by the physician or an appropriate physician extender (e.g., nurse practitioner). A medical record that lacks a date or physician signature is considered “invalid” and will not be reviewed.
  
• Acceptable physician authentication includes handwritten signatures, electronic signatures and signature stamps that can be identified as related to an acceptable provider type, (e.g., inpatient facility, outpatient facility or physician).
  

  • Electronic signatures must be authenticated by the provider at the end of each note. Some examples of acceptable electronic signatures are: “Electronically signed by,” “Authenticated by,” “Approved by,” “Completed by,” “Finalized by,” or “Validated by,” along with the practitioner’s name (including credentials) and date signed.
  

• Signature stamps are acceptable, provided they are permitted under state law and the physician has a current signature stamp authorization document on file in his or her office.
  
• All entries must be legible and complete, and must be authenticated and dated promptly by the person who is responsible for ordering, providing or evaluating the service furnished. Regardless of the record type, a consultation report with the typed name of the dictating physician should be signed by that dictating physician.
  
• For practitioner office and hospital outpatient visits, hospitals often send copies of dictated reports prior to review and signature by the provider. Diagnoses from these reports would not be coded or abstracted from a physician record unless the physician has documented them in the office record as reference for part of an office visit note. A note such as “see discharge summary from (date) hospitalization” or “see consultation report dated (date)” would be sufficient to link the current progress note to the dictated summary without having to rewrite all of the findings.

For more information about proper documentation of medical records, visit www.cms.hhs.gov.

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New Survey to Improve Provider Service

Every month, Humana receives more than 300,000 calls to its provider service line. In April, Humana implemented a system that randomly chooses a few thousand of those calls to provide brief, immediate feedback on how well service representatives responded to providers’ offices. The purpose is to help improve service to providers.

A similar member survey tool has been in place for consumers. Now, when physician offices call Humana, they occasionally are asked if they are willing to answer a brief survey about the service they received. If they are willing, they provide a call-back number to receive an automated survey immediately after their service call ends. The surveys take a minute or two and gauge overall satisfaction and whether or not the caller’s issue was resolved.

If the feedback is negative, a service recovery specialist is notified to contact the provider and rectify the situation.

“One of the metrics we’re trying to achieve is to better understand first-call resolution — how well we’re resolving calls during initial contact,” said Tim McClure, director of provider relationship management. “These surveys give us an indication of how well we’re solving issues. If we find that we need to better educate service reps or provide additional tools, we can do that. The project is part of our provider value proposition, which is focused on ensuring that Humana is the easiest payer with which to do business.”

In the future, Humana may expand the effort, depending on feedback.

“We are cognizant that a business is calling us, and we don’t want to intrude on physician practices’ work flow,” McClure added. “We believe the survey fits nicely with our provider ‘perfect service’ efforts and our ability to obtain and act on timely feedback to improve providers’ experiences with Humana.”

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