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'Reviewed by' meaning on a note

Julie Posted Tue 10th of December, 2013 09:10:58 AM

Our EHR system has changed recently, and we now have a new issue to deal with as a result. Previously, the program did not show any cosigners for a note - only the main providers electronic signature was on the printed notes. With the upgrade, the cosigner's name now also shows as an electronic signature, and reads "Cosigned and Reviewed by___________" with the date.

Since these cosign signatures never showed anywhere before, people other than providers have 'cosigned' the note in order to close it after doing edits. (only the billing manager cosigns in addition to the provider) We cannot remove or otherwise edit the old cosigns.

Is it acceptable to cross out only the 'cosigned by' so the line reads 'Reviewed by _______' (billing manager)to denote that another professional did review the notes but is not involved in the medical care? Or do we need to completely white out that entire line/signature that reads "Cosigned and Reviewed by___________" and copy the note without any of that?

We are trying to deal with the existing cosigned notes we cannot change as well as create our new policy around this, so your advice on this is much appreciated.

Please let me know if you need further info to properly answer the question. Thanks in advance!

SuperCoder Answered Wed 11th of December, 2013 02:56:26 AM

I would need to know whether the EHR you have now is certified (which is mostly like a yes) and what certification does it have? Also, what kind of facility are we talking about here and in the documentation of which part of facility does this cosigned portion appear, is it throughout the EHR for all settings (outpatient, inpatient, ER, etc?)? Is your facility taking part in any incentive programs and also which RAC do you fall under? Also, why do you think you need this new signature line to be rectified or abolished?

Initially, I would say that "cosigned and reviewed" line only signifies that the review was only in the capacity of a medical record professional/billing professional and not a medical review. The signature line for the provider should be separate than this new signature line.

The cosigned part is most likely put there by the EHR developers as a part of their certfication requirement, which would actually be also required to be addressed by your facility and the particular setting in which it is appearing. I would need the above mentioned info to be able to provide a solution that you can talk about to the EHR developers and also utilize to correctly put forward the "Cosigned and Reviewed by______" part.

Julie Posted Fri 13th of December, 2013 20:00:58 PM

Yes the EHR is certified - this is the disclaimer on the entrance page:

"This Complete EHR is 2014 compliant and has been certified by an ONC-ACB in accordance with the applicable certification criteria adopted by the Secretary of the U.S. Department of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services or guarantee the receipt of incentive payments. MediTouch EHR 4.0 was certified on June 13th 2013 (ID# 06132013-1962-8) and has been certified to Criteria 170.314: (a)1-15, (b)1-5&7, (c)1-3, (d)1-8, (e)1-3, (f)1-3, (g)2-4 and all of the CMS core CQMs including, CMS2v1, CMS50v1, CMS68v1, CMS69v1, CMS75v1, CMS90v1, CMS117v1, CMS126v1, CMS136v1, CMS138v1, CMS146v1, CMS153v1, CMS154v1, CMS155v1, CMS156v1, CMS165v1, CMS166v1, in addition, this certified product-version may require fees to establish interfaces for reporting to registries, public health agencies, and transmission of reportable laboratory tests and requires the use of the surescripts network for clinical interoperability and spreadsheet software"

We are a group pain management practice, seeing patients and doing procedures in the office. The cosign information only shows in the clinic operations when one views the overview list of all encounters for a patient in the EHR. It shows who treated the patient in one box, and cosigners in another box and so on. The boxes/columns are:

Service Date Finalized Appointment Rendering Signed By Cosigned By Options
(DOS) (date) (date) (rendering name) (e-signature) (cosigner name)

The cosign information is only seen when viewing this overview of all DOS. It does not show when someone views the note. It only appears when the pdf of the note is printed.

On the printed note, the provider signature prints along the left hand side of each page of records. This has always been the case, With this upgrade however, now the cosigner name is on the opposite side of the page from the provider with the "co-signed and reviewed by" along with the date of the review.If there are multiple cosigners on a note, only the first cosigners name appears.

We are doing the incentive with the G-codes and eRX, but we have not yet mastered Meaningful Use. We fall under RAC Connolly Consulting Associates, Inc

I personally felt the cosign signature could be left as is, but I was wanting to get a broader opinion on it to make sure that we had considered everything. You can't be too careful these days. I wasn't 100% sure what 'cosigned by" legally meant in this circumstance - as in 'Is co-signing a note something only a provider can do' ?. The actual note is very specific who the provider is at the beginning of the note where the patient, DOS, and insurance are identified. Again, the cosigner name does not appear anywhere at all until the actual note is printed, with the exception of the overview DOS list. Once you open a specific DOS, you cannot see any cosigner information.

Hopefully I answered all your questions adequately. I so appreciate Supercoder for this feature, and all of you who help us through the tough spots we encounter.

Thanks in advance

SuperCoder Answered Mon 16th of December, 2013 07:58:27 AM

Hi,

My expert colleague is deeply looking into the scenario here and will answer soon.

Thanks for trusting us!

Julie Posted Mon 16th of December, 2013 12:09:00 PM

Thank you for the in-depth help...
I would much rather have the right answer vs a quick one.

SuperCoder Answered Thu 19th of December, 2013 02:25:05 AM

The EHR has to maintain a capability for the following:
"Record actions related to electronic health information. The date, time, patient identification, and user identification must be recorded when electronic health information is created, modified, deleted, or printed; and an indication of which action(s) occurred must also be recorded."

With that in mind and the fact that the cosignee section appears when you take a print out of note, the cosign signature is required to indicate the user identification when the health information is being printed. The provider is required to sign it to validate on the health information being released/printed. The cosigner should be required to validate the user identification for the print requirement and maintain the accountability for the printing of the health information. The billing manager or the medical record professional responsible for releasing or upkeep of the medical records should suffice for the cosignee section. However, I would recommend that you contact the EHR vendor to obtain a valid list of signatories who can sign on the Cosignee section. I would recommend you do not leave the cosignee section as it is when sending out or using the printed health information unless you have a written information from the EHR vendor that reasonably allows you to do so within the purview of Meaningful Use criteria or any such criteria you might be obliged to follow. In the case that the EHR vendor recognizes the cosigner's section requirement as a mere additional feature or formality that is not required under any criteria you are participating in, the vendor might be obliged to remove this section altogether. I hope you would be adequately follow up with this issue.
Thanks and welcome.

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