Rubber-stamped signature by physician not accepted by HCFA
Question: Is it acceptable for physicians to use a rubber-stamped signature when signing the 700 or 701 forms? If the physician has already written a prescription for therapy, with a hand-written signature, would this be sufficient for Medicare? Also, must a 700 form be on file for each Medicare patient in an outpatient setting? I have been practicing this way for years; however, a colleague is tells me that we are not required to have a 700 on file, as long as there is a written prescription with frequency and duration as well the physician signature on the therapy evaluation.
Answer: This question contains several points that require clarification. There appears to be confusion over physician referral, the certification of need, a therapy evaluation and a patient plan of treatment (POT).
The physician referral (prescription) is the order for therapy and does not substitute for a POT. The certification and recertification of need must be reviewed and signed by the physician at least every 30 days. The evaluation and POT are not necessarily the same thing. The Health Care Financing Administration (HCFA) is very precise in its requirements for the information that needs to be included in a POT. For an evaluation to be considered a POT, it needs to contain the following, in addition to the objective tests and measures and identification of functional loss:
- Type of modalities/procedures;
- Frequency of visits;
- Estimated duration of treatment;
- Functional goals;
- Rehabilitation potential.
HCFA's Outpatient Physical Therapy, Comprehensive Outpatient Rehabilitation Facility and Community Mental Health Center Manual, Chapter 2 - Coverage of Services, §270, identifies the conditions that must be met for outpatient physical therapy, occupational therapy and speech pathology services to be covered: "No payment may be made for outpatient PT, OT or SP services unless a physician certifies that:
- A plan for furnishing such services is or was established by the physician, physical therapist, occupational therapist or speech-language pathologist and periodically reviewed by the physician (see §270.3);
- The services are or were furnished while the patient was under the care of a physician (see §270.2);
- The services are or were reasonable and necessary to the treatment of the patient's condition."
The manual goes on to state "since the certification is closely associated with the plan of treatment, the same physician who establishes or reviews the plan must certify the necessity for the services. Obtain the certification at the time the plan of treatment is established or as soon as possible thereafter. When services are continued under the same plan of treatment, the physician must recertify at intervals of at least once every 30 days that there is a continuing need for such services and must estimate how long services are needed. Obtain the recertification at the time the plan of treatment is reviewed since the same interval (at least once every 30 days) is required for the review of the plan. Recertifications are signed by the physician who reviews the plan of treatment. You may choose the form and manner of obtaining timely recertification. Retain certification by the physician and certify on the billing form that the requisite certification and recertifications have been made by the physician and are on file when the request for payment is forwarded." Further, "The patient's plan normally need not be forwarded with the claim but is retained in the provider's file. The provider must certify on the billing form that the plan is on file."
HCFA states in the Program Integrity Manual, Chapter 6 - Intermediary MR Guidelines for Specific Services, §8 - Forms HCFA-700/701, Outpatient Rehabilitation Services Form: "The outpatient rehabilitation services forms, Forms HCFA-700/701, are combined medical review (MR), certification/re-certification, plan of treatment (POT) forms for outpatient Part B, physical therapy (PT), occupational therapy (OT) and speech language pathology (ST)."
Use of the 700 and 701 forms meets the HCFA requirements regarding certification and the plan of treatment.
§8.1.1- Instructions for completion of Form HCFA 700, Plan of Treatment for Outpatient Rehabilitation, states in the instructions for completion of #15 - Physician's Signature, "The physician signs and dates this item if the Form HCFA 700 is to be used as the physician's certification. If you use an alternative signed certification form, the "On File" box should be checked (Item 18). Identify the period of certification in Item 17 on the HFCA 700. When certification is not required, the provider uses "N/A." Rubber signature stamps are not acceptable as the physician signature. The provider must keep the form containing the physician's original signature on file at the provider site."
To answer your question briefly:
- Medicare does not accept rubber-stamp signatures.
- The 700/701 forms must be on file at the provider's site if it is used for certification/recertification.
- A written prescription with frequency and duration does not meet the requirements for a POT.
- There needs to be evidence that the physician has reviewed the POT at least every 30 days prior to recertifying continued need.
Your fiscal intermediary (FI)/carrier may also have additional requirements that you must meet. For example, First Coast Service Options, Inc., the FI for Florida, in its draft Medical Review Policy for Physical Medicine and Rehabilitation, proposes a requirement that all providers maintain an established POT as a permanent part of the patient's clinical record. In addition, the physician must see the patient at least every 30 days during the course of therapy, must review, initial and date the POT at least every 30 days and keep the POT on file in his office, available for review if requested.
If you have a question about Medicare reimbursement you would like the authors to address, send your question and contact information to Medicare Advisor, c/o Linda Jones, ADVANCE for PTs & PTAs, 2900 Horizon Dr., King of Prussia, PA 19406; fax (610) 278-1425; firstname.lastname@example.org.
Pauline Watts and Danna Mullins are the co-founders of Encompass Education, Inc., a rehabilitation education and consulting firm in Palm Harbor, FL. You may contact the authors at email@example.com.