Lab Requisition Signature Requirement Postponed

The requirement for a physician’s or qualified nonphysician practitioner’s (NPP) signature on all requisitions for clinical diagnostic laboratory tests paid under the Clinical Laboratory Fee Schedule (CLFS) will not be enforced beginning Jan. 1, 2011, as finalized in the 2010 Physician Fee Schedule (PFS) final rule.

The Centers for Medicare & Medicaid Services (CMS) recently announced on its website that it will instead spend the first quarter in 2011 educating physicians, NPPs, and clinical diagnostic labs of this new policy. Educational and outreach materials will be made available on the CMS website as well as other communication channels. “Once our first quarter of 2011 educational campaign is fully underway, CMS will expect requisitions to be signed,” the agency states in its online announcement.

In the 2011 PFS final rule, CMS states (on page 1029):

“One of the reasons we made this proposal is because we believed that it would be less confusing for a physician’s signature to be required for all requisitions and orders, eliminating uncertainty over whether the documentation is a requisition or an order, whether the type of test being ordered requires a signature or which payment system does or does not require a physician or NPP signature.”

CMS goes on to clarify in the 2011 PFS final rule that this policy does not concern electronic or telephonic requests, because it does not consider these types of requests to be requisitions. “A requisition is the actual paperwork, such as a form, that is provided to a clinical diagnostic laboratory that identifies the test or tests to be performed for a patient,” CMS explains.

“However,” CMS further states in the 2011 PFS final rule, “this policy does not require a physician or NPP to use a requisition to request a clinical diagnostic laboratory test paid under the CLFS. Many physicians and NPPs currently request clinical diagnostic laboratory tests using an order … and they may continue to do so without being impacted by our new policy for requisitions.”

An “order” (as defined in the Internet Only Manual, Pub 100-02, chapter 15, section 80.6.1) is “a communication from the treating physician/practitioner requesting that a diagnostic test be performed for a beneficiary.

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