Yes. CMS says, "If you use a scribe, including artificial intelligence technology, sign the entry to authenticate the documents and the care you provided or ordered." CMS also says you don't need to document who or what transcribed the entry, and it doesn't require the scribe to sign or date the documentation. The provider's signature is the one CMS asks for.

What CMS says about scribes, including AI

"If you use a scribe, including artificial intelligence technology, sign the entry to authenticate the documents and the care you provided or ordered." (CMS, MLN905364)

What you don't need to document

"You don't need to document who or what transcribed the entry." (CMS, MLN905364)

"Note: We don't require the scribe to sign or date the documentation." (CMS, MLN905364)

Stamped signatures

"We don't usually accept stamped signatures." (CMS, MLN905364)

The exception CMS names: under the Rehabilitation Act of 1973, a rubber stamp is allowed "if the author has a physical disability and provides proof of their inability to sign due to their disability."

If a required signature is missing: attestation statements

"If your required signature is missing from a medical record (other than an order), file an attestation statement." (CMS, MLN905364)

"However, an attestation can't be used to backdate the plan of care." (CMS, MLN905364)

CMS also notes that MACs "may offer specific guidance on signature attestation statements", so check your own MAC's guidance too.

The 20-day window

When a review contractor needs a signature attestation or log, CMS says they'll "ask if the billing entity would like to submit an attestation statement or signature log within 20 calendar days." The 20 days start when the contractor makes phone contact with you or when you get the request letter.

"These timeframes don't apply to CERT review contractors." (CMS, MLN905364)

Signature logs

"You or your organization may create a signature log at any time. MACs accept all signature logs regardless of the date you created them." (CMS, MLN905364)

CMS also states what happens when entries fall short:

"If the entries don't meet the signature requirements, we may deny the associated claims." (CMS, MLN905364 (July 2025))

Desk checklist

This is a checklist built from the CMS lines above, not extra CMS text:

  1. The provider signs every scribe-drafted entry, including entries drafted with AI technology.
  2. No stamped signatures, unless the Rehabilitation Act exception CMS describes applies.
  3. Missing signature (not on an order)? File an attestation statement. It can't backdate the plan of care.
  4. Track the 20-calendar-day window when a contractor asks for an attestation or signature log.
  5. Check your MAC's signature-attestation guidance.

FAQ

Does the provider have to sign a note an AI scribe drafted?

Yes. CMS says, "If you use a scribe, including artificial intelligence technology, sign the entry to authenticate the documents and the care you provided or ordered."

Does the scribe have to sign the note?

No. CMS says, "Note: We don't require the scribe to sign or date the documentation."

Do I have to document that AI transcribed the note?

Not for Medicare's signature rules. CMS says, "You don't need to document who or what transcribed the entry."

Can I use a stamped signature?

Usually not. CMS says, "We don't usually accept stamped signatures." The exception CMS names is a rubber stamp under the Rehabilitation Act of 1973 "if the author has a physical disability and provides proof of their inability to sign due to their disability."

The signature is one requirement

signing meets the signature rule. the note still has to support the service.

Related resources

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Source: CMS, MLN905364, Complying with Medicare Signature Requirements (MLN fact sheet, July 2025). All quotes above are from this fact sheet.