Unauthorized Electronic Signatures Used on MSP Forms
Penalty
Summary
The facility failed to safeguard resident-identifiable information and maintain medical records in accordance with accepted professional standards by allowing unauthorized use of electronic signatures on Medicare Secondary Payer (MSP) forms. Specifically, a staff member (NF3) electronically signed MSP forms on behalf of several residents and their representatives without obtaining proper authorization or consent. This was discovered when another staff member noticed a large number of MSP forms being printed in quick succession, which raised concerns about the feasibility of obtaining legitimate signatures in such a short time frame. Further investigation revealed that the residents and their representatives were unaware of the MSP forms and had not authorized or signed them. Interviews with staff confirmed that NF3 admitted to electronically signing the forms to catch up on outstanding documentation. Review of the affected residents' MSP forms and the facility's validation documents confirmed that the signatures were unauthorized. The facility's policies require that only authorized individuals use electronic signatures and that access to electronic medical records is strictly controlled, but these protocols were not followed in this instance.