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

Twenty-nine healthcare organizations, including the American Hospital Association (AHA), sent CMS a letter December 3 opposing what they termed the "redundant and burdensome" signature requirement that CMS announced in the 2011 Medicare Physician Fee Schedule final rule, published November 29. The AHA coalition asked CMS to delay implementation until January 1, 2012.

Instead of a year-long delay, CMS announced on its website that it is concerned that some physicians, non-physician practitioners (NPP), and clinical diagnostic laboratories were unaware of or did not understand the new policy. As a result, CMS will spend the first quarter of 2011 educating providers. "Once our first quarter of 2011 educational campaign is fully underway, CMS will expect requisitions to be signed," CMS noted in its announcement.

The biggest benefit for providers is they will now have more time to educate their medical staff and other facilities, such as nursing homes, says Patti Reisinger, RHIT, CCS, HIM Director at Community Medical Center in Missoula, MT.

The delay also provides facilities with additional time to re-develop forms. Reisinger spoke with a colleague at another facility who is currently revising lab requisitions and orders to include the physician's name and some other shortcuts for physicians.

"My initial take was, 'Isn't it nice that CMS is recognizing that folks may need more time to adjust to major policy changes,'" says Jugna Shah, MPH, president of Nimitt Consulting in Washington, DC. "On the one hand, it seems reasonable that CMS would want to give providers additional time to prepare for this sort of change, yet it's also curious since this is out of the ordinary for CMS."

So what else might be behind the delay?

Shah thinks one reason may be the ongoing pressure from AHA and other organizations to repeal the requirement altogether. "If CMS thinks it might have to repeal this, then maybe the agency realizes that it shouldn't implement it now just to have providers go back to the way things were," she says.

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