Virtual Medical Scribe Services
A virtual medical scribe is a remote team member who writes the clinical note while the clinician treats the patient. The clinician reviews and signs it, and under Medicare the clinician's signature is the one that counts.
Written by Salman Saeed, CEO and Co-Founder · Reviewed by a Certified Medical Coder · Last reviewed October 2026- 97%client retention
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Included with Our Billing
What every billing client gets.
- EHR or PM softwareFree for every billing client.
- No setup feeNo fee to set up your billing.
- Old A/R workedAt no extra fee.
- A dedicated account managerIncluded for every billing client.
- Patient billingPatient statements and patient billing calls, at no extra fee.
- Monthly performance reportsIncluded with your billing.
In short: a remote scribe drafts the note, the treating clinician signs it, and the signature is what Medicare looks for. Remote scribes who touch patient records also need a HIPAA business associate agreement with the practice.
What Does a Virtual Medical Scribe Do?
A virtual medical scribe records the encounter in the chart so the clinician can look at the patient instead of the screen. The scribe does not act independently. One Medicare contractor, WPS, describes the role as documenting the physician's dictation or activities during the visit, with the physician delivering the service and creating the record.
Nucleus Align provides virtual medical scribes as one of our 22 services. The work sits next to medical coding, because the note is what a coder reads to assign codes, and next to virtual medical assistants, who handle front-office tasks rather than clinical documentation.
The list on the left follows the encounter elements the CMS E/M guide (MLN006764, May 2026) says a visit record should show: the reason for the encounter, relevant history, examination findings and prior test results, the assessment, and the plan of care.
Who Signs the Note When a Scribe Writes It?
The treating physician or non-physician practitioner (NPP) signs. The Medicare Program Integrity Manual, chapter 3, section 3.3.2.4, says that when a scribe documents a medical record entry such as a progress note, CMS does not require the scribe to sign or date the documentation.
The same section says the treating physician's or NPP's signature on the note indicates that the physician or NPP affirms the note adequately documents the care provided. That wording is in the version issued by Transmittal 12633 on May 9, 2024, effective June 10, 2024.
Why the Clinician's Signature Matters
Section 3.3.2.4 says signatures are required on medical review for two purposes: to satisfy a specific signature requirement in statute, regulation or a coverage determination, and to resolve authenticity concerns about the documentation. A note with a missing or illegible signature can therefore still be reviewed, but an unsigned note invites an authenticity question.
| Signature tool in section 3.3.2.4 | What it is | Key rule from the manual |
|---|---|---|
| Handwritten signature | A mark or sign on a document showing knowledge, approval, acceptance or obligation | Stamped signatures are not typically acceptable; an exception exists for an author with a physical disability |
| Electronic signature | A signature applied in an electronic system | The system should be protected against modification and use administrative procedures that match recognized standards and laws |
| Signature log | A list that ties typed or printed names to initials or illegible signatures | Reviewers shall not deny a claim for a log missing credentials |
| Attestation statement | A statement signed and dated by the author of the entry | It must contain enough information to identify the beneficiary; the contractor asks if you want to submit one within 20 calendar days |
Section 3.3.2.4 also states that an attestation from someone other than the author of the entry is not considered. A scribe cannot attest on the clinician's behalf.
What Documentation Rules Apply to Scribed Notes?
Scribed notes follow the same rules as any other note. The CMS E/M guide says the medical record should be complete and legible, and that documentation should be made during the encounter or as soon as possible after it.
The guide also says your MAC may ask for documentation to confirm the site of service, the medical necessity of the services, and that you report services correctly. A note a scribe drafts is judged on those same points.
- The clinician reviews the whole note against what happened in the room.
- The clinician corrects anything the scribe heard wrongly or left out.
- The clinician signs and dates the note.
- The signed note is what goes to coding and into any records request.
Split or Shared Visits in Hospitals and EDs
When a physician and an NPP share a visit, the rule is different from scribing. The CMS E/M guide says the person who performed the substantive portion of a split or shared visit must sign and date the record, and the record must identify both practitioners.
For ED, hospital outpatient and inpatient visits, the guide defines the substantive portion, from January 1, 2024, as more than 50% of total time or a substantive part of the medical decision making. A scribe's time and writing do not make a scribe one of the two practitioners. See billing for EDs and freestanding ERs for how that plays out in claims.
Is a Virtual Medical Scribe HIPAA Compliant, and Do You Need a BAA?
A remote scribe from an outside company handles protected health information on your behalf, so HIPAA requires a business associate agreement between you and that company. Under 45 CFR 164.504(e), the contract must establish the permitted and required uses and disclosures of the information by the business associate.
Under 45 CFR 160.103, a business associate is a person who creates, receives, maintains or transmits protected health information for a function or activity on behalf of a covered entity, other than as a member of that entity's workforce. A vendor's scribe working in your chart fits that definition.
Under 45 CFR 164.504(e)(2), the contract must also require the business associate to:
- Use appropriate safeguards and, for electronic information, comply with the HIPAA Security Rule (subpart C of 45 CFR part 164)
- Not use or further disclose the information other than as the contract permits or the law requires
- Report to you any use or disclosure the contract does not allow, including breaches of unsecured information
- Make sure its subcontractors that handle the information agree to the same restrictions
- Return or destroy the information at termination if feasible, and keep no copies
Under 45 CFR 164.504(e)(1), if you learn of a pattern of material breach by a business associate, you must act to cure it or, if that fails, end the arrangement where feasible.
Nucleus Align signs a Business Associate Agreement with every client. For the rest of our controls, see security and HIPAA.
Can Scribes Improve E/M Coding Accuracy?
A scribe does not choose the level, but a complete note makes the right level visible to the coder. The CMS E/M guide says the medical record documentation must support the level of service you report to a payer.
For office and outpatient visits, E/M levels are selected using medical decision making (MDM) or total time, and the guide says history and examination are medically appropriate to the visit but are not elements in choosing the level. The guide points to the AMA's E/M Services Guidelines for the MDM elements, and we do not reproduce AMA text here.
| What the CMS guide says | What it means for a scribed note |
|---|---|
| The treating clinician determines the nature and extent of the history and examination | The scribe records what the clinician asks and finds; the clinician decides what is appropriate |
| The care team may collect information, reviewed by the reporting clinician | Intake details can be gathered by others, but the clinician must review them |
| You do not use the volume of documentation to decide the level | A longer note does not raise the level; the decision making must support it |
| Show the specific sign, symptom or complaint that makes the service reasonable and necessary | The note should state the reason for each service billed |
Our coders read signed notes and send questions to the clinician when the record does not support a code. That is part of medical coding, and billing and coding audits check whether notes support what was billed. We state no coding-accuracy figure for scribed notes.
Illustrative only. A clinician bills a high-level ED visit, but the note records only 'chest pain, EKG normal, discharged.' The assessment, the reasoning and the risk considered are missing, so a reviewer cannot see the decision making. A coder's query to the clinician is the fix, before the claim goes out.
Talk to a Billing Lead.
A 20-minute call about your payers, volume and setup. Monday to Friday, 9am to 5pm Eastern.
Does Scribe Documentation Reduce Denials?
Better notes remove one cause of denials and record requests, but we give no denial-reduction figure for scribes. A payer or MAC that reviews a claim reads the record for site of service, medical necessity and correct reporting, according to the CMS E/M guide.
When a claim is denied for documentation, the record request lands on the signed note. How we work denials is on the denial management page, and how we handle records is on medical records management.
How Does a Virtual Scribe Work, and Which EHRs Can Scribes Use?
The Medicare manual does not prescribe a method, so a remote scribe can work from a live audio or video connection or from the record after the visit. The CMS E/M guide only asks that documentation be made during the encounter or as soon as possible after it.
We align each EHR, clearinghouse and payer portal workflow with verified team experience, standard claim validation, reconciliation controls and performance monitoring. The systems we work in are listed on the EHR and PMS systems page. Tell us which workflow your site needs on a call and we will say what fits.
What About Patient Consent, AI Documentation and Cost?
Consent for a scribe in the room is a policy and state-law question, and no federal consent rule is cited here, so check your state law and your payer contracts. Ask your compliance counsel what your state and payers require.
A human scribe is a person who drafts the note, and AI documentation tools generate drafts by software. The section 3.3.2.4 text refers to scribes and does not mention AI tools. In both cases the treating clinician's signature is what affirms the note.
Our published pricing is on the pricing page. We make no comparison against in-person scribes here.
How We Handle Virtual Scribe Work
Our scribes are part of a team based across our offices in Vancouver, BC, Dubai, UAE and Islamabad, PAK, plus our registered office in Richmond, KY. Remote staff work under the controls below.
- A Business Associate Agreement with every client
- HIPAA training and NDAs for all staff
- Two-step login on every system
- Encrypted automatic backups
- A dedicated compliance officer
To talk through which of your providers would use a scribe, and in which EHR, book a call.
- Medicare Program Integrity Manual, Transmittal 12633: Signature Requirements (chapter 3, section 3.3.2.4) · CMS
- Evaluation and Management Services (MLN006764) · CMS Medicare Learning Network
- 45 CFR 164.504 Uses and disclosures: organizational requirements · eCFR
- 45 CFR 160.103 Definitions (business associate) · eCFR
- Guidelines for the Use of Scribes in Medical Record Documentation · WPS Government Health Administrators (copy hosted by ACEP)
We check every rule, code and deadline against the official source. See our editorial policy.
Who We Do This For
Common Questions
Straight answers from the team that does the work.
Ask a billing lead directly. A 20-minute call, Monday to Friday, 9am to 5pm Eastern.
01What does a virtual medical scribe do?
A virtual medical scribe is a remote team member who documents the encounter in the chart for the clinician to review and sign. The scribe records what the clinician says and does. The clinician decides the diagnosis, the plan and the billing level, and signs the note.
02Who is responsible for the final note?
The treating physician or non-physician practitioner. Medicare Program Integrity Manual chapter 3, section 3.3.2.4, says that practitioner's signature on a note indicates they affirm it adequately documents the care provided. The scribe does not take over that responsibility, and the clinician reviews before signing.
03Does a scribe have to sign the note for Medicare?
No. Section 3.3.2.4 of the Medicare Program Integrity Manual says CMS does not require the scribe to sign or date the documentation. The treating practitioner's signature is what matters. Some MACs publish their own scribe templates, so check what yours asks for.
04Is a virtual medical scribe HIPAA compliant?
A scribe from an outside company is a business associate under 45 CFR 160.103, so you need a business associate agreement under 45 CFR 164.504(e). We sign a Business Associate Agreement with every client and train all staff on HIPAA, with NDAs.
05Can scribes improve E/M coding accuracy?
They help the record show the decision making, which the coder needs. The CMS E/M guide says documentation must support the level billed and that volume of documentation does not set the level. The clinician still decides the level, and we state no accuracy figure.
06How does a virtual scribe work: live during the visit or from recordings?
The Medicare manual does not require either method. The CMS E/M guide asks for documentation during the encounter or as soon as possible after it. Tell us on a call how your site works and we will say what fits.
07Which EHRs can scribes work in?
We align each EHR workflow with verified team experience, standard claim validation, reconciliation controls and performance monitoring. The EHR and PMS systems page lists the systems we work in, so check there for yours, and book a call if yours is not listed.
08How much does a virtual scribe cost compared with an in-person scribe?
Our published pricing is on the pricing page. We do not compare against in-person scribes here because we have no sourced figure to compare. Book a call to discuss your providers, your settings and the EHR your scribes would work in.
09Do scribes work in emergency departments and urgent care?
WPS guidance covers scribe use in an office or a facility setting. For shared ED visits, the CMS E/M guide says the practitioner who performed the substantive portion must sign and date the record. Scribing does not change who bills.
10How do you handle patient consent for scribe use?
No federal consent rule for scribes is cited here, so check your state law and your payer contracts. Consent for a scribe depends on your own policy and on state law, so ask your compliance counsel what your state and your payers require before you start.
11What is the difference between a human virtual scribe and AI documentation?
A human scribe is a person who drafts the note, and AI tools draft by software. The Medicare manual section refers to scribes and does not mention AI. In both cases the treating clinician's signature affirms the note.
12Does scribe documentation reduce denials?
A complete, signed note answers the points a reviewer checks: site of service, medical necessity and correct reporting, per the CMS E/M guide. We give no denial-reduction figure for scribes. Denials themselves are worked under our separate denial management service.
Talk to a Billing Lead.
A 20-minute call about your payers, volume and setup. Monday to Friday, 9am to 5pm Eastern.