Palmetto: Lab Ordering Trends are Problematic

Independent clinical/pathology laboratories and in-house laboratory services performed by medical practices are under one Medicare Administrative Contractor’s looking glass. Palmetto GBA recently published an article that identifies problematic ordering trends noted during a review process.

The Palmetto review staff examined records for several claims related to laboratory errors for which denials for testing procedures were generated to better address problems identified during reviews conducted by the comprehensive error rate testing (CERT) contractor.

For every claim selected for review, Palmetto found “recurring, widespread problems with various aspects of the ‘ordering’ process,” and the reason procedures were deemed medically unnecessary by CERT and denied.

Problematic ordering trends, Palmetto says, include:

  • Absence of any type of requisition, order or valid documentation of “intent” by the ordering-treating physicians or qualified non-physician practioners (NPPs);
  • Preprinted test requisition forms did not include signature/initials of the ordering/treating physicians or qualified NPPs;
  • Preprinted laboratory requisitions or orders were complete and signed/initialed only by auxiliary staff, not the ordering physician or qualified NPP; and
  • For lab service performed and submitted by practices in-house, the patients’ medical charts or progress notes were somewhat illegible, did not list or even mention the test or blood draws, and/or did not meet Medicare’s signature requirements.

Palmetto found when the ordering/treating practitioner’s staffs are contacted directly by CERT, the offices fail to respond to direct requests for corroborating documentation, orders, medical chart notes, etc. When information is supplied, the patients’ records are often unacceptable because the records are unsigned and/or omit any reference to the tests being ordered.

Palmetto reminds practitioners that if they do not reply to CERT follow-up requests, or send insufficient/invalid records, Medicare will hold the billing laboratory financially responsible for any incorrect payments.


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