"When rubber stamp signatures are authorized by the facility's management, the individual whose signature the stamp represents shall place in the administrative offices of the facility a signed statement to the effect that he/she is the only one who has the stamp and uses it. A list of computer codes and written signatures must be readily available and maintained under adequate safeguards."
This is the only place in the OBRA regs for SNFs that rubber stamp signatures are referenced.
Rena
Rena R. Shephard, MHA, RN, FACDONA, RAC-C
President, RRS Healthcare Consulting Services
17210 Russet Street
San Diego, CA 92127
858-592-6799
858-592-6800 (fax)
858-254-0851 (mobile)
[EMAIL PROTECTED]
Subj: Re: Second try - Surveyors here! Who needs to sign the MDS?
Date: 2/21/04 3:50:32 PM Pacific Standard Time
From: [EMAIL PROTECTED]
Reply-to: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Sent from the Internet
Sherry et al:
Below is a section of Illinois Amdinistrative Code 300.1810, Resident Record Requirements (italics mine). Note the reference is to physician use of a rubber stamp. This may be what the surveyor was referring to. I could find no reference in the Illinois Adm. Code that addressed staff use of a rubber stamp, but if the physician is not allowed, I can see the surveyors following the logic that staff couldn't either. This section if the IAC also addresses the issue of an electronic medical record. It can be accessed at http://www.legis.state.il.us/commission/jcar/admincode/077/07700300sections.html
Please respond to me privately - I'd be interested in knowing who was doing the presenting!
Nancy
[EMAIL PROTECTED]
d) All physician's orders, plans of treatment, Medicare or Medicaid certification, recertification statements, and similar documents shall have the authentication of the physician. The use of a physician's rubber stamp signature, with or without initials, is not acceptable.
(Source: Amended at 23 Ill. Reg. 8106, effective July 15, 1999)
----- Original Message -----
From: Sherry Salinas
To: [EMAIL PROTECTED]
Sent: Saturday, February 21, 2004 12:12 PM
Subject: Re: Second try - Surveyors here! Who needs to sign the MDS?
Have been participating in a Life Services Network audioconference series on the RAI process over the last few weeks. The presenter is a former Public Health Surveyor, just stopped doing it in the last few months. She specifically said that when she was covering the signature requirements. Of course, we know surveyors are sometimes not quite clear on things, but she seemed very sure. Should I take it with a grain of salt, do you think?
Sherry
Nathan <[EMAIL PROTECTED]> wrote:
Where did you learn this and in what context? Rubber stamping has a number of uses. In some situations the States may have regs governing their use, but they don't write the CMS/MDS policies.
Nathan
----- Original Message -----
From: Sherry Salinas
To: [EMAIL PROTECTED]
Sent: Friday, February 20, 2004 1:53 PM
Subject: Re: Second try - Surveyors here! Who needs to sign the MDS?
I learned 2 wks ago that rubber signature stamps are NOT allowed in IL.
Sherry
Nathan <[EMAIL PROTECTED]> wrote:
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"
To:
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...
