Wiki Post-dated UDS Requisition

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lethr77

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Hi guys! I am looking for some clarity regarding Urine Drug Screens and whether or not a post dated requisition form would be permissible for a urine sample collected without an order in the first place. In my current situation, the lab did not inquire about the requisition form until 8 days post collection. I am not comfortable billing out something that wasn't ordered at time of collection, as it was not, from my perspective, deemed medically necessary at the time of the appointment.

I appreciate any insight you can provide. Thank you!!
 
SharonCollachi said:
Well, who exactly ordered the UDS?
Click to expand...
I work for a PCP with an in-house, fully CLIA certified lab. Our Doctor and NP's order the urine drug screens for our patients, monthly, unless they determine otherwise. The issue I am having is that, as things are presently, urine is collected prior to any orders being placed and our lab then runs everything without verifying an order exists. It appears the lab is asking the providers to create an order after the presumptive or confirmatory tests have been run, when no order was placed at the time of service, as it was deemed not necessary.
 
So what you're saying is, it's a standing order for UDS for patients. That's a no-go for pretty much every insurance company I am aware of. At the visit, they need to put in the order for the next month's test. So at the visit June 15, they order the UDS for the next visit, which should be based on standard risk factors (like a SOAPP-R), which is generally twice a year for low risk, 4 times a year for moderate risk, and monthly for high risk. For someone with low risk factors, there is no medical necessity for testing them monthly. It cannot be based on a standing order for all patients or because it's what the doctor decided. Should anyone come up positive for alcohol, we require them to test monthly no matter what risk category they fall into, until they have at least 3 consecutive tests of no alcohol.
 
That's what I've been telling my providers for a year now. I thought the issue had been resolved last year, however it seems to have reared it's ugly head again. I just wanted to double check that I was not incorrect on this. Thank you @SharonCollachi! I greatly appreciate the confirmation!
 
Here is what Medicare says:

Recognizing the Meaning of Standing Orders
PUBLISHED ON FEB 04 2016, LAST UPDATED ON NOV 21 2019


Medicare will consider payment for appropriately documented covered services that are reasonable and necessary for the beneficiary, given his/her clinical condition. Medical necessity is the driving force for the payment of any Medicare service. If a service is not medically necessary, it cannot be paid by Medicare. Providers need be cognizant of the various meanings represented by use of the term "standing orders." Some understand this to mean recurring orders specific to the care of an individual patient, while others understand this as routine orders for services delivered to a population of patients. The following can help you understand the various uses of "standing orders."

Routine Orders
Routine orders are orders for those services and treatments that are applied to patients who have the same or similar medical condition(s). These frequently called "routine, protocol or standing orders" are based on an assessment of the impact of a given condition in the population of patients with that condition (medical illness or injury) and are widely applied to those patients. Medicare defines any order(s) that does not specifically address an individual patient's unique illness, injury or medical status, as not reasonable and necessary. As is required by law, Medicare does not accept such "standing orders" as supporting medical necessity for the individual patient. Services related to population-based or condition-based orders are not reimbursable.
 
Agreed, and would also just add a link to a good reference here that addresses this - the first sentence on page 3 of this education document states: "You cannot create missing orders after the fact to backdate a plan of care or other service. If the medical record has no order for a service, Medicare will deny payment for the service."

However, it adds that for some unsigned orders, you may "submit progress notes showing the intent to order the tests" (if your record has these).

 
Not to pile on, but your laboratory needs to change it's operational processes immediately. And just to confirm, are you saying that your family practice has implemented definitive testing via say, Liquid Chromatography, and has a high complexity CLIA license? Is your laboratory director aware that there is no order?

What is run on the instrument is not what we bill. The specimens when placed on an instrument will be run for every test on your menu, that is how the instruments are set up- this is true across labs no matter the size. You bill for what has been ordered, so no order- no test- no bill. If you are a CLIA certified laboratory, and you are performing moderate or high complexity testing there are test requisition requirements specific to your accrediting facility and CLIA. Standing orders, customized panels are non-covered benefits and do not meet medical necessity requirements. There is a tremendous amount of scrutiny around standing orders, in fact was on a webinar today specifically discussing standing orders and they are being discouraged across the industry with the exception of inpatients.

My recommendation, without any further information is that you immediately stop testing until each individual providers documentation has been reviewed to ensure that the test order is being documented. Just as a heads up- "order UDS" or "Order Drug Testing" will not insulate a provider from a clawback.
 
Hi guys! Thank you for all of your feedback. I'm aware of all of this information and have been battling for lab work in general to be done properly since it was fully brought in-house. This is a far more complicated issue and I have been fighting a solo, uphill battle.

I have shared all of the information, yet again, and have now been removed from coding and billing responsibility for the labs as of last week. I tend to be a problem child when it comes to these things, I guess, in trying to implement and enforce the following of proper guidelines.
 
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