The regulation requires that "all staff responsible for completing any part of the MDS, MPAF, and/or tracking forms must enter their signatures, titles, sections they completed, and the date they completed those sections" at item AA9 (RAI User's Manual, p. 3-11). Individuals signing at AA9 are attesting to the accuracy of the information they entered on the MDS.
The regulation does not permit the use of electronic signatures (which are not the same thing as signature stamps). Page 1-27 states, "Until such time as CMS adopts an electronic signature standard that is compatible with (HIPAA) requirements for electronic signature, all facilities are required to sign and retain hard copies of the MDS."
The requirement for the RNAC is to sign to verify completion of the MDS at R2b and VB2 as applicable. If you are signing at AA9 as well, you are attesting to the accuracy of those items. If you are not the one filling out those items, you would need to be verifying the accuracy of the MDS responses before you attested to their accuracy in AA9.
Rena
Rena R. Shephard, MHA, RN, FACDONA, RAC-C
Chair, American Association of Nurse Assessment Coordinators
[EMAIL PROTECTED]
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of
Doyle, Renee
Sent: Friday, February 20, 2004 2:18 PM
To: '[EMAIL PROTECTED]'
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...
