Physician Certification Forms and the Inpatient Order
In recent weeks we have had questions from a couple of our clients about “Inpatient Admission Order / Certification of Medical Necessity” forms. Remember that CMS does not require the use of a Physician Certification form but is looking for good documentation in the History & Physical and Orders to support the 2-Midnight Expectation, an Authenticated Inpatient Admission Order and evidence of Discharge Planning.
What we have found is that at times the Attending/Certifying MD would complete the “Inpatient Admission Order” portion of these forms but was not co-signing the actual Inpatient Order that was written by a physician or practitioner without admitting privileges. The concern is whether or not this would meet the Authentication of the Admission Order requirement.
As a result, we submitted the following scenario and question to the Provider Outreach and Education division at Cahaba, GBA the Medicare Administrative Contractor (MAC) for Alabama, Georgia and Tennessee.
- Patient presents to the ED for care.
- The ED MD does not have admitting privileges.
- The ED MD discusses the case with the Attending Physician and the decision is made to admit the patient as an inpatient.
- The ED MD writes “bridge” orders including the status order “admit to inpatient.”
- The Attending “acknowledges” the Inpatient Admission Order on the “Inpatient Admission Order / Certification of Medical Necessity Form” but does not co-sign the actual ED MD’s admit order.
- Per CMS guidance, an admission order written by a practitioner who does not have admitting privileges is not valid unless it is authenticated by a countersignature.
Question: Does the signature of the attending physician on the certification form serve to authenticate the admit order? In other words, is there a valid admission order if the actual ED physician “bridge order” is not co-signed by the Attending Physician?
Cahaba, GBA’s Answer: “No, the order would need to be co-signed by the attending physician in order for it to be considered valid.”
Article by Beth Cobb
This material was compiled to share information. MMP, Inc. is not offering legal advice. Every reasonable effort has been taken to ensure the information is accurate and useful.