In July 2025, the Centers for Medicare & Medicaid Services (CMS) released updated guidance on complying with Medicare signature requirements, including new information on stamped signatures, artificial intelligence (AI), and the use of signature attestations and logs. These updates clarify how medical documentation must be authenticated to meet Medicare billing requirements and help providers avoid denials due to missing or illegible signatures.
Medical reviewers rely on signatures to validate that services were provided or ordered by the appropriate practitioner. If documentation lacks a valid, legible, and dated signature, claims may be denied unless a valid signature attestation or log is submitted.
Key points from the revised guidance include:
- Stamped signatures are not generally accepted unless the provider has a physical disability, as outlined under the Rehabilitation Act of 1973.
- When using a scribe—including AI tools—providers must still sign and date entries to authenticate the documentation.
- Signature attestations are permitted when a required signature is missing from most types of medical records, although they are not allowed for missing signatures on orders.
- Signature logs can be submitted at any time, regardless of when they were created, to help reviewers match illegible signatures to the correct practitioner.
- Providers have 20 calendar days to respond when contractors request a signature attestation or log, and an additional 15 calendar days may be added to the review timeline if documentation is submitted.
The guidance also reinforces existing requirements for dating signatures, use of electronic signatures, and procedures when relying on documentation from medical students.
Access the updated guidance from CMS here.
Compliance Perspective
Issue
CMS has updated its guidance on complying with Medicare signature requirements, with important clarifications related to stamped signatures, AI, and the use of attestations and signature logs. These updates highlight the importance of valid practitioner signatures and the consequences of missing, illegible, or improperly authenticated documentation. As providers increasingly adopt electronic systems and digital tools, including scribe and AI-based documentation support, it’s important to ensure that all documentation is properly signed and dated. Failure to meet signature requirements can lead to claim denials and delayed reimbursement, particularly during medical review or audit processes.
Discussion Points
- Review your documentation policies to ensure they include clear processes for verifying practitioner signatures, including those involving AI-generated or transcribed content. Facilities should also establish procedures for handling missing or illegible signatures through attestations and signature logs. Working with a consultant can help identify gaps and ensure your practices align with CMS expectations across all types of documentation.
- Provide targeted training to appropriate staff on signature requirements, including how to properly authenticate entries created by AI tools or scribes. Training should also cover when and how to use signature attestations and logs, and the risks associated with missing or noncompliant signatures.
- Review clinical and billing documentation to verify the presence and legibility of practitioner signatures. Pay particular attention to high-volume services or records likely to be requested during medical review. A focused chart audit—possibly with input from an external reviewer—can help ensure your facility is prepared to support the authenticity of your documentation.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*