On November 30, 2017, a new state rule (13 CSR 65-3.050) will be effective for electronic signatures in the MO HealthNet Program. The new rule establishes the basis on which health care providers and participants under Missouri Title XIX programs may use electronic signatures when validating services rendered and received.
As defined in the new rule, an “electronic signature” means a computer data compilation of any symbol or series of symbols executed, adopted, or authorized by an individual with the intent to be the legally binding equivalent of the individual’s handwritten signature. The use of biometrics does not constitute an electronic signature; however, biometrics may be used as part of electronic signature verification. A signature stamp or typing the name of the provider or participant on a form does not constitute an electronic signature. If a law or regulation requires a signature to be in writing, an electronic signature shall satisfy such law for MO HealthNet purposes.
Providers are not required to conduct business electronically, but if they choose to do so – they need to comply with the requirements of the new electronic signature rule. The new rule does not eliminate the requirement for certain Home and Community Based Services (HCBS) providers to utilize telephony/electronic visit verification.
All providers are encouraged to review the requirements of the new rule. There are specific requirements for any electronic signature system, including (but not limited to) the tracking of: (1) User log-in and log-out dates and times; (2) User identification; (3) Device Identification; (4) Dates and times when records are created, updated, viewed, or modified; and (5) The process of affixing an electronic signature shall require at least two (2) distinct identification components, such as an identification code and a password.
Any questions regarding the proper use of electronic signatures for services that will be billed to MO HealthNet should be directed to Missouri Medicaid Audit & Compliance (MMAC) at 573-751-3399 or MMAC.General@dss.mo.gov