CMS Proposes to Rescind Lab Requisition Signature Requirement

After 10 years, the requirements for signatures on lab requisitions are still in flux.

CMS is now proposing to rescind the requirement for signatures on all lab requisitions that it previously finalized in the 2011 Medicare Physician Fee Schedule (MPFS) last November, according to the “Medicare Program; Clinical Laboratory Fee Schedule: Signature on Requisition” notice of proposed rulemaking (NPRM) published in today’s Federal Register.

“This is great news,” says Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc., in Danvers, MA. “This is one instance where the comments of providers, labs, and other stakeholders were considered in greater detail and they made a positive impact on the final outcome.”

Per the 2011 MPFS final rule, a physician’s or nonphysician provider’s (NPP) signature is currently required on lab requisitions for tests paid under the clinical lab fee schedule, regardless of whether there is a signed order. This is the opposite of prior CMS rulings that indicated signatures were not required on requisitions, although written and signed orders were required.

The requirement was scheduled to take effect January 1, however, in light of significant commentary by the healthcare industry, CMS granted a delay in enforcement so providers could conduct education and outreach during the first quarter of 2011.

“It was during that time that CMS decided to re-examine the policy instead,” Mackaman says.