CMS had since hinted that the requirement might be rescinded, but that doing so would require additional rulemaking as it had already been finalized in the 2011 MPFS rule. Today’s proposed rule fulfills that requirement.
“Stakeholders provided excellent examples of how the real world works when ordering lab in a variety of scenarios. This just goes to show that we must take the initiative to comment on proposed rules because it can make a positive impact on CMS rulings,” Mackaman says. “[CMS] began to understand the burden this would place on providers since the requisition is primarily a ‘business document’ to initiate a test, often used by staff per a provider’s order. The order and/or documentation to support the service is still required so signing a request to initiate a test was considered to be redundant and unnecessary.”
CMS also states in the rule that it underestimated the effects the signature requirement could have on quality of care and patient safety as providers took time to obtain signatures. This is especially true for providers without electronic health records or for those who hadn’t combined their requisition and order form into a single document.
The requirement for signatures on lab requisitions was mainly an effort on the part of CMS to continue to reduce fraud and improper payments.