Medicare Question (Full Version)

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MickeyPT -> Medicare Question (December 28, 2007 7:18:43 PM)

I am a clinic director for an outpatient PT practice in Missouri.  Our owner insists that we need a patient sign in sheet for Medicare compliance.  He says that we need the patients signature as proof that they were at our clinic otherwise there is no proof that we are billing legit.  I told him that I'm not comfortable with a sign in sheet due to HIPAA but he discredits my fears stating that there is no violation of HIPAA policy.  The sign in sheet sits on the front counter where everbody can see.  If we absolutely MUST have it I suggested that we use stickers that will be removed after each patient signs in.  Can anyone tell me if a sign in sheet is necessary for Medicare and/or an email address to someone who can provide me with evidence regarding this dilemma?  Thanks.  Mickey



hmgross -> RE: Medicare Question (December 29, 2007 2:37:56 PM)

Sign in sheets are not violating HIPAA policies, but I fail to understand how a person's signature could "prove" you are billing them correctly.  I guess it proves they attended, but so what.  Your documentation does that, and Medicare patients get statements regarding services rendered.  Just recently, a TV news program showed a little lady in Florida going over her bills and thousands of $$ of treatment she didn't receive, so I suppose it would be up to the beneficiary to read statements and report any signs of abuse or fraud.



SJBird55 -> RE: Medicare Question (December 30, 2007 7:53:05 PM)

I have not read anything in Medicare rules and regulations for independent physical therapists in an outpatient setting billing under Medicare B to capture a signature of the patient.  Documentation requirements for physical therapists practicing in this setting do not have patient signature as an established, expected protocol.

What I do because I have reported fraud in the past and there could be a chance that someone might choose to retaliate.... 1) every patient signs in on a label (name, date, time)  2) every patient signs out on a label (name, date, time)  3)  my office manager clocks patients in and clocks patients out in the scheduler.

After every patient signs in or out, the label is peeled off and stuck on his/her own individual sign in/out sheet.  Once the patient is discharged, this sheet is scanned into the medical record. 

What I have implemented somewhat establishes that the patient was in attendance, so the patient couldn't come back and dispute a date of service.  (It is just extra protection for me.)  It also assists with total time in the clinic (to capture the non-billable time).  What I like about it is that in all honesty, if records were audited, there would be cases where there would be discrepancies in sign in and sign out times along with the clocked in and out times because in the real world, my office manager can't always do it perfectly because of the phone or walk-in prospective patients or initially being in the middle of some other task. 

My personal opinion on the matter of having a sheet of paper in which patients sign in.... if anyone can read the signatures, then technically the simple fact that the patient has received services isn't confidential. 

Signatures really don't create the situation that you really are billing for services provided.  There are cases that I have heard of in which patients attend one visit and sign in multiple times for "services" (4 weeks or so at a time) and bills are generated for those services.  The patient was never treated.... The appearance would be a patient was legitimately treated, but if you put a camera up in that clinic, you would soon see the fraud occurring.



hmgross -> RE: Medicare Question (December 31, 2007 1:12:32 PM)

I would view a sign in sheet no differently than a nurse announcing a patients name in a waiting room at the clinic.  We have a small place and practice in a very small town so 75% of the time, the other patients know each other ( it seems we constantly remind people not to ask someone "why are you here?).  We don't dovetail any visits so there really is no "incentive" to bill for anything other than the time we do our one-on-one with them.  Of course there is always room for fraud, so short of videorecording every session, I rely on documentation.  I have been through an audit, shortly after I took over the director position at our hospital.  Very poor documentation by a couple therapists and several thousand dollars were returned to Medicare.  The administrator wanted me to appeal all of them, but I didn't.  One example was a ther ex charge, and all the PT wrote that day was "corrected hamstring stretch"  Other therapists will see you, say "go ahead and get started on that machine and I will be right back" yet charge for the entire time "on the clock".  It is a complicated issue, and I don't think there is any one right solution.  Go with your gut, I guess.  



MickeyPT -> RE: Medicare Question (December 31, 2007 6:22:48 PM)

Thank you both for the input.  My fears have been comforted and I'm feeling a little more comfortable with the idea of a sign in sheet...but I will probably follow SJBird's advise and have them sign a label of some sort that can be "hidden" from other patients.  I became fearful of a HIPAA violation after a couple of patients recognized the names of other patients on the sign in sheet.  None of my previous jobs have ever required a sign in sheet for patients so naturally, I had to question the validity of our owners statement that it was "required".  Even if it isn't required by Medicare...what can it hurt? Thank you once again for responding.  -Mickey



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