Delay in Signature Requirements for Clinical Laboratory Testing

CMS has delayed the implementation of their revised policy requiring a signature of the physician or nonphysician practitioner on orders for clinical diagnostic laboratory tests. In the November 29, 2010, Medicare Physician Fee Schedule final rule, the Centers for Medicare & Medicaid Services (CMS) finalized its proposed policy to require a physician’s or qualified nonphysician practitioner’s (NPP) signature on requisitions for clinical diagnostic laboratory tests paid under the clinical laboratory fee schedule effective January 1, 2011. A requisition is the actual paperwork, such as a form, which is provided to a clinical diagnostic laboratory that identifies the test or tests to be performed for a patient. Although many physicians, NPPs, and clinical diagnostic laboratories may be aware of, and are able to comply with, this policy, CMS is concerned that some physicians, NPPs, and clinical diagnostic laboratories are not aware of, or do not understand, this policy. As such, CMS will focus in the first quarter of next year on developing educational and outreach materials to educate those affected by this policy. As they become available, we will post this information on our Web site and use the other channels we have to communicate with providers to ensure this information is widely distributed. Once our first quarter educational campaign is fully underway, CMS will expect requisitions to be signed.