CMS Notifies Contractors Not to Enforce Physician Signature Ruling

By | April 23, 2011

In a Joint Signature memorandum dated March 31, 2011 CMS has notified it’s contractors not to enforce the requirement to have a physician or NPP signature on paper requisitions for clinical diagnostic laboratory tests paid under the clinical laboratory fee schedule, and will focus for the remainder of 2011 on changing the regulations. This change came about largely due to a focused effort of the clinical laboratory community who contact lawmakers to tell them what a burden requiring physician signatures on paper requisitions would cause for any clinical laboratories doing outreach testing.

From Dark Daily:

“We believe the fact that 89 members of the House of Representatives and 34 members of the U.S. Senate signed a letter to CMS recommending that the rule should be repealed had a significant effect on the decision,” Birenbaum commented. “And those who signed the letter were both Republicans and Democrats and they were about equally split.”

Here is the text of the memo:

RE:  Joint Signature memorandum (RO-7728, 03-31-11) JSM/TDL – 11258

In the Monday, November 29, 2010, Medicare Physician Fee Schedule final rule, the Centers for Medicare & Medicaid Services (CMS) finalized its proposed policy to require a physician’s or qualified non-physician practitioner’s (NPP) signature on requisitions for clinical diagnostic laboratory tests paid under the clinical laboratory fee schedule effective Saturday, January 1, 2011.  (A requisition is the actual paperwork, such as a form, which is provided to a clinical diagnostic laboratory that identifies the test or tests to be performed for a patient.)

On Monday, December 20, 2010, CMS informed its contractors of concerns that some physicians, NPPs, and clinical diagnostic laboratories are not aware of or do not understand this policy.  As such, CMS indicated that it will focus in the first quarter of 2011 on developing educational and outreach materials to educate those affected by this policy.  CMS indicated that once the first quarter educational campaign is fully underway, it will expect requisitions to be signed.

After further input from community, CMS has decided to focus for the remainder of 2011 on changing the regulation that requires signatures on laboratory requisitions because of concerns that physicians, NPPs, and clinical diagnostic laboratories are having difficulty complying with this policy.

For a more detailed report on this issue visit Dark Daily.

Category: Legislative

About J.R.

Rodric Consulting, LLC is a Clinical Laboratory Consulting company specializing in providing consulting services for hospital or health system based laboratories in a variety of areas, including CLIA, Productivity and Non-Labor savings, and Interim Management consulting.