Why We Are No Longer Accepting Verbal Signatures on Treatment Plans

At Texas Care, we are committed to protecting our clients, our clinics, and our company by maintaining strong documentation practices. For that reason, we have updated our policy and will no longer accept verbal signatures on treatment plans.

While verbal signature functionality was added as a feature in Notenetic, Texas Care Franchises under the MSA are not accepting it as an approved method for treatment plan completion.

Why This Change Was Made

Treatment plans are one of the most important documents in a client’s file. They are not just paperwork. They are meant to reflect the goals being worked on, the needs being addressed, and the direction of services being provided.

A verbal signature does not adequately protect the clinic or the Franchisor during an audit because it does not clearly demonstrate that the parent or Legally Authorized Representative (LAR) reviewed, understood, and agreed to the treatment plan goals.

This matters because auditors and payors do not just look for whether a treatment plan exists. They may also want to know whether the parent or LAR truly understood what was being signed and what services were being provided in support of those goals.

Why This Matters During Audits

One of the concerns with verbal signatures is that they create room for doubt. If a treatment plan is challenged, a verbal acknowledgment may not provide the same level of protection as a signed document.

OIG and Managed Care Organizations may contact clients or families during an audit or investigation process to ask questions about the services they received, including whether they were aware of their treatment plan goals. If a parent or LAR does not understand the goals or is unaware of them, that can raise serious concerns about the validity of the documentation and the services billed under that plan.

That kind of issue can place payments at risk and may lead to recoupments. A treatment plan that is clearly and indisputably signed helps protect both clinic owners and the Franchisor from unnecessary financial exposure and potential legal or compliance issues.

A Signed Treatment Plan Protects Everyone

A properly signed treatment plan helps show that:

• the plan was reviewed with the parent or LAR

• the goals were discussed

• the parent or LAR had the opportunity to ask questions

• there was clear acknowledgment and agreement

From an operational standpoint, this is simply the stronger standard. It creates cleaner documentation, reduces avoidable audit risk, and better supports the integrity of the client record.

In my opinion, this is the right move. If a treatment plan is important enough to guide care and support billing, then it is important enough to be properly signed. Verbal acknowledgment may feel easier in the moment, but it does not provide the same protection when documentation is being closely reviewed later.

What Staff Should Do Moving Forward

If a treatment plan needs to be reviewed and signed, staff should ensure that time is set aside to go over the treatment plan with the parent or LAR and obtain the required signature.

Charge case management to review the treatment plan and obtain signatures when appropriate.

Because this is a community-based program, QMHPs are expected to make reasonable efforts to go to the parent or LAR when needed in order to obtain signatures, especially if the LAR is unable to sign digitally.

The expectation is not simply to note that the plan was discussed. The expectation is to ensure the treatment plan is properly signed and completed.

Digital Signing and Parent Portal Update

At this time, the parent portals are currently down. However, Notenetic has advised that the parent portals are expected to be fixed by 04/29/26.

Once available, digital signing should help streamline this process for families who are able to complete signatures electronically.

There are also instructions available on theTexas Care Support site that walk staff through how to guide the LAR in setting up their PIN and signing the treatment plan.

Final Thoughts

We understand that this change may create some extra work in the short term, especially while portal access is limited. But this policy change is being made for a reason. It strengthens our documentation, better protects clinics during audits, and helps ensure that treatment plans truly reflect informed participation by the parent or LAR.

At the end of the day, treatment plans should not just be “completed.” They should be reviewed, understood, and properly signed. That is better for compliance, better for audit readiness, and better for the long-term protection of everyone involved.