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Reliance on Standing Orders
Although standing orders are not prohibited in connection with an extended course of treatment, too often they have led to abusive practices. Standing orders in and of themselves are not usually acceptable documentation that tests are reasonable and necessary. Accordingly, the insurer may reject standing orders as evidence that a test is reasonable and necessary. Medicare contractors can and may require additional documentation to support the medical necessity of the test. As a result of the potential problems standing orders may cause, the use of standing orders is discouraged.
Thus, while laboratory compliance programs may permit the use of standing orders executed in connection with an extended course of treatment, the compliance program should require the laboratory to periodically monitor standing orders. Standing orders should have a fixed term of validity and must be renewed at their expiration. We suggest that, consistent with State law requirements, a laboratory should contact all nursing homes from which the laboratory has received such standing orders and request that they confirm in writing the validity of all current standing orders. In addition, in accordance with State law, laboratories should verify standing orders relied upon at draw stations with the physician, authorized person on the physician’s staff, or other authorized individual who has provided the standing orders to the laboratory. With respect to patients with End Stage Renal Disease (ESRD), at least once annually laboratories should contact each ESRD facility or unit to request confirmation in writing of the continued validity of all existing standing orders.
D5301Â§493.1241 Standard: Test request.
(a) The laboratory must have a written or electronic request for patient testing from an authorized person.
Interpretive Guidelines Â§493.1241(a)
An “authorized person” means an individual authorized under State law to order tests or receive test results, or both. If the State law does not address who may order tests and receive test results, then anyone may order tests and receive test results. However, the laboratory must follow the requirements in the Social Security Act regarding test ordering for reimbursement under Medicare.
To assure only the authorized person is ordering the test, a laboratory using electronic test requests may issue passwords.
Use of standing orders should be clearly defined in written policy, describing which tests may be covered by standing orders and at what interval standing orders should be reconfirmed.
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