The Centers for Medicare and Medicaid to stop April implementation
The just-in requirement for physician signatures on lab test requisitions won’t happen after all, as per a CMS statement to lab groups that lobbied to stop the change.
Initially it was the January 1, then the April 1 deadline passed for referring physicians and non-physician practitioners (NPP) to personally sign all paper requisitions for clinical lab tests.
Labs heave a sigh of relief: The new policy was going to mean a big change since existing Medicare policy specifically doesn’t require a doctor signature on clinical lab test requisitions.
Lab Group announces CMS retraction
The American Association of Bioanalysts (AAB) and National Independent Laboratory Association (NILA) groups that headed a lobbying effort against the physician signature rule — announced that CMS has determined the physician signature rule is unworkable and that the best thing to do is to pull it back in its present form.
You should be aware of the current rules
According to the Medicare Benefit Policy Manual (CMS IOM Pub. 100-02, chapter 15, §80.6.1), no signature is required for clinical diagnostic tests paid on the basis of the clinical laboratory fee schedule, the physician fee schedule or for that matter physician pathology services. The just-in requirement put forward in the 2011 PFS final rule would supersede this long-standing policy.
By stating that the agency won’t implement the physician signature requirement on April 1, CMS reverts to the standard put forth in the Benefit Policy Manual.
You should get proactive for signatures
Does that mean you should forget the agency’s most recent physician signature scare and maintain the status quo in your lab?
Many think the physician signature requirement is not gone forever. Remember that CMS said only that it would pull it back in its present form.
Try this: Labs should understand the latest recommendation and get ready to comply, even though the agency won’t implement the change this month. You should put a signature space on requisitions when you are reprinting and start to train staff and clients to get a signature.
Better still: Work to move your lab toward electronic orders that do not need a signature.
In order to help you understand what almost happened, and what labs might face in the future if the agency decides to reprise the rule, read on for a review of the policy that CMS published in the 2011 Physician fee Schedule (PFS) final rule Nov. 29, 2010 Federal Register):
Know signature scope that almost was
In the 2011 PFS, CMS states that the new physician/NPP signature requirement is for requisitions for clinical diagnostic lab tests paid under the Clinical Laboratory Fee Schedule (CLFS).
Paper only: The signature requirement would’ve applied only to paper requisitions. This policy doesn’t affect physicians or NPPs who opt not to use paper requisitions to request clinical diagnostic laboratory tests paid under the CLFS. Such physicians or for that matter NPPs can continue request such tests by other means, such as by using the annotated medical records, documented telephonic requests, or electronically.
May be – anatomic pathology: Even though the PFS policy would have required physician/NPP signatures for paper requisitions for clinical diagnostic lab tests paid under the CLFS, some experts are of the opinion that the requirement would have extended to tissue specimens for anatomic pathology.
This is because CMS states that the change would mean a physician’s signature would be “required for all requisitions and orders, eliminating uncertainty over … which payment system does or doesn’t require a physician or NPP signature.” The agency goes on to define a requisition as “the actual paperwork, such as a form … which may comprise… information for specimens or tissue samples…” Together, these statements mean that physicians or NPPs must also sign requisitions accompanying anatomic pathology specimens.
Canceling the physician/NPP signature requirement put forth in the 2011 PFS final rule will make all these considerations null and void. This is an important issue for CMS; as such you should be prepared to deal with the matter another day.
For more on this and for other specialty-specific articles to assist your pathology coding, sign up for a good medical coding resource like Coding Institute.