EMS PCR Signatures Explained: Compliance, Audits, Complete Reports 

At our recent webinar, EMS Billing Compliance: Preventing Costly Documentation Mistakes, one topic that flooded the Q&A was crew signatures. 

“Is it a requirement for both crew members to sign the PCR or just a recommendation?” 

“Why would a crew member who isn’t the primary provider need to sign?” 

“We get push back because the one driving doesn’t know exactly what the other provider did in the back.” 

The answer to the first question is no, in most states it isn’t a requirement to have both crew members sign the patient care report (PCR). But it is strongly recommended as a legal and compliance best practice. Let’s dive into why, which will answer the rest of the questions. 

Fully Staffed Ambulance

To be considered a valid transport, the EMS agency must be licensed with the state to provide services, the ambulance needs to have the appropriate supplies, and it needs to be fully staffed. Federal regulations require an ambulance to be staffed by at least two people who meet the requirements of state and local laws where the services are being furnished. In other words, to be a valid transport, an ambulance must be staffed by two or more crew members. 

Ambulance agencies submit claims to most payers electronically, so do not have to submit PCRs, documentation, or other proof of transport in order to be paid. However, you are required to maintain all records of the transport including proof of compliance with vehicle and staff licensure and certification requirements which auditors, investigators, or oversight agencies can request at any time. 

Authenticating the Record

Medicare requires that anyone responsible for providing care or services to beneficiaries be identifiable. If an auditor has concerns about the legitimacy of the documentation they can require verification of signatures, seek an attestation from providers who did not sign, or, if neither can be obtained, deny the claim. 

Because ambulance transport requires at least two crew members, if only one crew member signs the PCR there is no proof the other crew member was present other than their name being entered on the report. Auditors can, and have, required agencies to obtain attestation statements from crew members who didn’t sign originally for each claim where there was only one signature. If the attestation statement couldn’t be obtained from the second crew member, the claim was denied.  

Audits typically happen years after the transport took place, so in the event you were required to obtain attestation statements, the crew members who didn’t sign the PCR may no longer be employed by your agency. Those otherwise valid claims would be denied because both crew members didn’t sign at the time of transport. 

Drivers and Secondary Providers 

The guidance on signing medical records says even in cases where two individuals are in the same group, one shouldn’t sign for the other in medical records or attestation statements. This supports the idea that second or additional crew members, even when they aren’t the primary provider, should sign the PCR. When the primary provider signs they are signing as the author of the report and attesting to the care they personally provided, not what was done by the other crew member(s).  The signature of the second crew member provides proof of their presence during the transport and attests to the care or services they personally provided to the patient whether it was an assessment, a single intervention, driving the ambulance, or being present to fulfill staffing requirements. 

Compliant and complete EMS patient care reports should include space for all crew members to be properly identified with their name, credentials, role, and signature.