All forms submitted to MMAC must have an original handwritten signature or a verifiable electronic signature using an electronic signature software such as; DocuSign,Adobe Sign, DropBox Sign.Some of these software offer free limited accounts.
If in the course of reviewing your documents an unverifiable or altered form utilizing electronic signature is found or suspected, providers will be required to either submit the original documents showing the authentication trail meeting the requirements below or produce new forms with valid handwritten signatures.
All Medicaid providers using electronic signatures must meet the following requirements:
• Implement a reliable method of verifying the identity of the signing party. To ensure the validity of the electronic signature, the provider must produce the digital certificate or any other tracking trail document showing the authenticity of the signature. The certificate should include but not limited to: Signing E-mail address, time stamp, IP addresses.
• Retain the certified and unaltered original documents and the Certificate of Completion for a minimum of five (5) years. The electronic document and signature should be kept secure to preserve its integrity by preventing unauthorized changes and maintaining the completeness of the agreement. DocuSign, Adobe Sign, and Dropbox Sign files are subject to the document retention requirements outlined in the provider’s Title XIX Participation Agreement, 13 CSR 70-3.030(3)(A)(4), and the appropriate MO HealthNet Provider Manual.
For questions, contact MMAC.
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
