In my opinion you may have a problem. While rubber stamps are allowed, the intent was that everyone completing part of the MDS would apply their rubber stamp to the paper form. CMS still has no official policy regarding the type of electroinic signing of the MDS that you are talking about. In talking to various people at CMS they verbally state that a secure system, such as you apparently have, should be ok, but there is nothing in writing to that effect. The MDS is still a paper system and relies on putting ink to the paper for a signature. If there is an appeal process, you may be able to argue the case. All the software vendors will be very interested in the outcome as we have been rying to decide where to go with this issue..
Good luck. Nathan ----- Original Message ----- From: "Doyle, Renee" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]> Sent: Friday, February 20, 2004 11:18 AM Subject: Second try - Surveyors here! Who needs to sign the MDS? > Sent this yesterday and got only one response. Surveyors are here - please > respond if possible. Thanks! > > Currently in the middle of a Public Health survey (Illinois), and they > aren't happy that I (RNAC) am the only one signing the MDS. We have an > electronic audit trail that shows each entry made to the > MDS/Date/Time/Name/Credentials and have a policy in place to support the > electronic signature. I told them that although other people enter > information in the computerized form, I am the one to review/edit/complete > the form. They were not happy with this explanation. Page 3-212 of the MDS > manual says under Clarifications: The use of signature stamps is allowed > (with policies in place). This was brought up on a past inspection, at > which time no one was physically signing (before my time), and they said > that an RN must sign in all places. Since I have been here (3 yrs) I have > been signing in every place needing a signature. They had been fine with > that until today. Now, they want everybody to sign. I think I have read in > the past on this listserve that other SNF's also have only the RNAC sign > without a problem. Do I have a case or am I out of compliance with the > policy? Please respond ASAP as they are due back in the a.m. with the exit > interview at 2 pm. By the way, they also thought the 5 day MDS had to be > done by day 5! They also couldn't understand why I wasn't doing a 5-day > Medicare on my Insurance patients. They told me you can't just pick any day > you want for the reference day. I had to copy several pages of the manual > to show them because they didn't believe me! Then I made the mistake of > giving them the manual to look at when they asked me for a copy. I think > they were embarrassed to be so uninformed. So, they are probably looking > for anything they can think of... > /---------------------------------------------------------- > The Case Mix Discussion Group is a free service of the > American Association of Nurse Assessment Coordinators > "Committed to the Assessment Professional" > Be sure to visit the AANAC website. Accurate answers to your > questions posted to NAC News and FAQs. > For more info visit us at http://www.aanac.org > -----------------------------------------------------------/ > /---------------------------------------------------------- > The Case Mix Discussion Group is a free service of the > American Association of Nurse Assessment Coordinators > "Committed to the Assessment Professional" > Be sure to visit the AANAC website. Accurate answers to your > questions posted to NAC News and FAQs. > For more info visit us at http://www.aanac.org > -----------------------------------------------------------/ > /---------------------------------------------------------- The Case Mix Discussion Group is a free service of the American Association of Nurse Assessment Coordinators "Committed to the Assessment Professional" Be sure to visit the AANAC website. Accurate answers to your questions posted to NAC News and FAQs. For more info visit us at http://www.aanac.org -----------------------------------------------------------/
