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Beneficiary Signature Requirement - Positive Change

July 17, 2014
AAA Member Advisory
TO:          AAA Membership
FROM:      David M. Werfel, Esq. 
RE:           Beneficiary Signature Requirement - Positive Change

When the patient is unable to sign the form requesting payment and authorizing the release of records due to a physical or mental condition, the request may be executed on their behalf by a legal guardian, relative, representative payee or representative of an institution providing care.
 
Until now, the person signing on behalf of the patient was required to also list their name, address, relationship to the patient and reason the patient could not sign.
 
Over two years ago, I asked CMS to remove the requirement of the address, when one of the Medicare Administrative Contractors (WPS) notified ambulance suppliers the address was required. The requirement of the address of the person signing on behalf of the patient was impractical as there was no space on the 1500 form for it, no field for it on electronic claims, it was not required in the CMS Regulation (42 C.F.R. 424.36) and the industry would usually not be able to obtain it.
 
After many follow-ups, CMS has removed the requirement in Transmittal 2984.
 
https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2984CP.pdf
 
In sum, the address of the person signing on behalf of the patient is no longer needed.

Guaranteed cash flow during transition.