This is a recommendation, not a requirement:
- As always, the initial physician certification and the 14 day certification can be signed and dated at admission. Nursing can fill in the required information, but a physician must date as well as sign the document.
- There has not been (nor has any regulation been updated) a requirement for timing. That in the past has been a function of inpatient/acute documentation, not skilled nursing.
- However, since facilities have gone to electronic medical record (and thus time stamping) increasingly auditors are looking for the time it was signed to be on the physician cert.
- What seems to be under scrutiny by auditors/fiscal intermediaries (MAC, RAC, ZPIC) is the time the physician signed the first certification and the 14 day. It is expected that the “time stamp” would show, for example, 10:01 am for the initial certification and 10:02 am for the 14 day. Never should the second certification be signed before the initial cert.
Programs are now electing to add “time” to their hard copy form (or if you are electronic making sure a time stamp appears). If you are still using a form:
- Remember that ANY MISSING INFORMATION on a physician cert phone is grounds no payment or returned payment.
- If the form is deemed incomplete in any manner, it is a technical denial – there is NO appeal process.
If you are a program that never has the physician sign both the admission and 14 day certification at the same time, adding a spot for a physician to time as well as date is probably not worth the risk of an incomplete physician cert.
Either way, your program should have a self-audit process for making sure all the certifications are signed and dated timely.