Who Signs What, and How Often?

The PCS Form
     I've discussed this requirement in the past (Physician Statements of Medical Necessity, May 2007), but I have not discussed who can actually sign these forms. This is one of those areas where the rules and publications seem to contradict each other. The rules (Code of Federal Regulations) seem to say that for some instances (mainly repetitive, nonemergent trips), these forms must be signed by a physician. However, other Medicare publications state that the form may be signed by an MD, PA, NP, CNS, RN or discharge planner. I personally like to see them signed by an MD just to avoid the issue, but there are times when no MD is involved in the patient's care. As to how often these forms must be signed, for a nonrepetitive, nonemergent transport (i.e., a hospital discharge or transfer), you should get a form for the specific date of service. For repetitive, nonemergent trips (e.g., dialysis) the forms are good for 60 days from the date they are signed.

     I hope this list is helpful and will serve as a reference for signature requirements. Of course, the rules may change again next week, so stay tuned. I'll keep you posted.

G. Christopher Kelly is an attorney who focuses on federal laws and regulations as they relate to the healthcare industry and specifically to the ambulance industry. This article is not intended to be legal advice. Contact Chris at ckelly@emscltd.com.