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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
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