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CMS Delays Enforcement of Signature Requirement on Lab Orders

Michelle Leppert, CPC-A, for HealthLeaders Media, December 22, 2010

Requisition or order?

CMS is adamant about requiring all lab requisitions to be signed if the lab receives them, regardless of whether a signed order is on file at the lab or in the physician's office, says Debbie Mackaman, RHIA, CHCO, Medicare Boot Camp® Instructor for HCPro, Inc, in Danvers, MA. "CMS' purpose is to reduce confusion on signatures that are required for orders–basically when is an order a requisition and vice versa."

Part of the problem that CMS seems to be trying to resolve with the requirement that all requisitions be signed is the location of signed orders. A signed order is often on file at the physician's office and not readily available to the hospital that performs the lab service based on a requisition which, to date, has not required a signature, Shah says. If the hospital lab had to produce a signed order to justify billing for the lab test, it may run into problems; a signed requisition can serve as the order in these situations.

CMS defines an order as a communication from the treating physician or practitioner requesting that a lab perform a diagnostic test for a beneficiary. Orders may be conveyed via:

  • A written document signed by the treating physician/practitioner that is hand delivered, mailed, or faxed to the treating facility
  • Telephone call
  • E-mail or other electronic means

CMS says a requisition is the actual paperwork, such as a form, that the physician provides the clinical diagnostic laboratory to identify the test or tests he or she wants performed. The requisition may contain patient information, billing information, specimen information, and test selection. CMS stated in the final rule that a requisition signed by a physician may serve as an order, to minimize confusion about signed orders vs. unsigned requisitions going forward.

"I have seen many facilities combine their order and requisition form into one document, so basically the requisition is always signed because it is also the order," Mackaman says.

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