Comment on Proposed Updates: Electronic Signatures

We appreciate DMAS’s continued efforts to ensure accountability and integrity in documentation for DD services. The updated focus on the structure and standards of electronic signatures is important and appreciated.

However, we respectfully suggest that this focus appears somewhat misplaced when viewed in the broader context of current documentation practices. Providers are still permitted to utilize handwritten notes or Word documents. These methods are far more susceptible to backdating, alteration, or other compliance vulnerabilities. This raises the question of whether the current emphasis on tightening requirements only for electronic health records (EHRs) is the most efficient or equitable approach.

Since the 2014-15 shift encouraging providers to move toward EHR systems, it seems more aligned with long-term Medicaid goals to prioritize universal adoption of secure, certified electronic health record systems. EHRs inherently offer time-stamped, tamper-evident records.

Focusing regulatory energy on strengthening compliance within already compliant EHR systems, while continuing to allow easily alterable handwritten or Word-processed notes, may inadvertently discourage EHR adoption despite their greater transparency and security.

A more balanced approach may be to:

• Reaffirm and promote the original intention to transition all providers to EHR systems,
• Provide clear timelines or incentives for full EHR adoption,
• Then, build compliance standards on that more secure and modern foundation.

Thank you for the opportunity to provide input.