Monday, June 30, 2003

e-CMNs: Here’s how you do it
With Jane Bunch

Q. Is there any reason I shouldn’t embrace e-CMNs?

A. Electronic CMN’s are now accepted as a means for a provider to obtain a signed CMN from the prescribing physician. Per the Medicare Program Integrity Manual, Chapter 5, “a supplier must either mail the front and back of a CMN, send a faxed CMN, or transmit both sides of the CMN electronically to the physician, nurse practitioner, physician assistant, or clinical nurse specialist for completion of Sections B and D.” The provider must retain a copy in their files and be able to provide it to the DMERC in the case of an audit.

What the provider must remember is it is the supplier’s responsibility to prove that the signature on the CMN is valid. Many consultants and healthcare attorneys have suggested that providers still obtain an “original ink signature” in the case the DMERC finds a claim that may not have actually been ordered by the physician that signed the order. CMS allows providers to accept electronic signatures as original signatures. Under the 2000 e-sign law, electronic signatures have the same legal effect. For providers entering the e-CMN arena, I believe this will suffice as your original signature. Keep in mind, the electronic CMN must be an exact replica of the original CMS form.

It is time to implement e-CMN’s (electronic signatures) into your corporate structure. It will decrease DSO’s and increase revenue flow.

Jane W. Bunch is CEO and founder of Jane’s Billing Service & Consultation. Reach her at 678-445-1221.