YOUR OPINION: Dr. must put signature on all lab tests ordered

[jsherrie]

Recent ASCP notification concerning the proposal that Dr.'s must sign for all test requisitions -

Physician Signature Requirement Burdens Labs, Jeopardizes Patients

ASCP urges you to act before the Jan. 3 deadline

Recently, the Centers for Medicare and Medicaid Services (CMS) finalized its Medicare Physician Fee Schedule final rule for the 2011 calendar year. The rule includes a troubling policy change requiring 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 Jan. 1, 2011). CMS defines a requisition as "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." Currently, a physician signature is required only on orders for laboratory services.

ASCP believes the new rule could adversely affect patient care and complicate the provision of the laboratory services. In cases where a signature from the ordering physician or NPP is absent, laboratories could be left scrambling trying to obtain the signature.

Late Breaking News Rule: Recently CMS has partially agreed to a delayed implementation request from ASCP and other members of the clinical laboratory coalition organizations. CMS will delay implementation of the rule for three months. During this period, ASCP will continue to pressure CMS to withdraw its new proposal.

ASCP urges you to contact CMS and tell them of your opposition to the policy change.

Contact CMS before the Jan. 3 Comment Deadline to maximize the effectiveness of your voice.

[trondint]

Signatures on Requisitions for Clinical Diagnostic Laboratory Tests

In the November 29, 2010 Medicare Physician Fee Schedule final rule, the Centers for Medicare and 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 calendar quarter of 2011 on developing educational and outreach materials to educate those affected by this policy. As they become available, we will post this information on our website and use the other channels we have to communicate with providers to ensure this information is widely distributed. Once our first quarter of 2011 educational campaign is fully underway, CMS will expect requisitions to be signed.

Source: http://www.cms.gov/ClinicalLabFeeSched/

[David Saikin]

we require signature of ordering provider on all of our outpatient reqs. For in pts, the MD orders are in the chart so those pts are covered.

[khalidm3]

Here since long, it is necessary for the clinicians to sign all the orders.

[Bill]

CMS rule has been delayed 3 months according to a 22Dec2010 memo posted on their website. We now have until 01Apr2010 to get it in place. FYI, as far as I can find, the electronic signature issue is not defined in the CMS final rule.

[Eagle Eye]

That is the same we have but new CMS rule(as far as I know) requires physician signature on lab requests.

we require signature of ordering provider on all of our outpatient reqs. For in pts, the MD orders are in the chart so those pts are covered.

[kathL]

Ok, I have been out of the loop for awhile. Does this mean that tests we did automatically (antibody identification on positive antibody screen samples) would require extra documentation of the physician's signature?

[Likewine99]

I don't think the antibody ID would need an MD signature or additional order. It is considered part of the type and screen procedure.

You could word your T&S procedure to include something to the effect of "specimens exhibiting positive antibody screening results are further tested to identify the unexpected antibody".

Antibody identification is part of the process we use to guarantee the safest, most compatible unit for the patient.

[Eagle Eye]

antibody ID, patient antigen typing, donor antigen typing, prenatal antibody titer are more or less reflex tests.

eg. in hematology if dr. Order CBC and automated CBC has a flag, you will automatically read the smear.

[adiescast]

CMS has dropped this requirement from the ruling.

[Generic]

Here's a link to an article about the dropped signature requirement.

http://www.healthdatamanagement.com/news/Report-CMS-to-Scrap-Lab-Signature-Requirement-41911-1.html

[Marilyn Plett]

From the AABB Weekly Report:

CMS Rescinds Lab Requisition Signature Requirement

The Centers for Medicare and Medicaid Services has decided to rescind its policy requiring a physician or qualified nonphysician practitioner's signature on requisitions for clinical diagnostic laboratory tests paid under the clinical laboratory fee schedule. The American Association of Bioanalysts has posted a notice on its website stating that a senior CMS official informed the group that the requirement would be rescinded prior to its April 1 effective date. The policy, originally included in the 2010 Medicare Physician Fee Schedule final rule, was meant to limit coverage for medically unnecessary tests but had caused widespread concern in the laboratory and long-term care communities, with many expressing that it would disrupt patient care. CMS initially delayed enforcement of the policy, which was set to take effect Jan. 1, as reported in the Jan. 7 issue of Weekly Report. Because CMS has yet to issue any official guidance on this rescission, providers are urged to stay abreast of developments relating to this policy.

[lateonenite]

Hmm. Here a clinician (or reg, resident or intern under a clinician) must sign the request (either electronically or on paper) because of Medicare billing - a doctor with a provider number must request a test for that test to be billed back to Medicare by the pathology service. I think (not sure, but I think) that private health insurers use the same requirement - easier than re-creating the wheel for themselves.

Tests performed in the lab are covered by a declaration on most requests which says something along the lines of the clinician assigning rights to the pathologist to perform tests as necessary (so...my Ab screen is positive, guess I'd better run a panel...LUCKY!) "as defined by laboratory procedure". If memory serves. I've only read it on requests a million times.

The only time it causes a lot of drama here is when a doctor wants an add on and doesn't see why they need to fill in the paperwork - the rules say 14 days to chase up an appropriately signed request, or Medicare will not pay - in general pathology it's a golden rule that no paperwork, no test. Of course, what usually happens is the tech will run the test (it's usually a fibrinogen on a bleeding patient, natch, would you like some cryoprecipitate with your order?) and put nothing in the LIS until the request is received. Blood Banks are a little different. In one health service, no paperwork, no crossmatchee with limited use of phone requests (or billing throws a major spit). In another, phone requests are the only way product orders are placed - beyond the original signed group and hold.

Medicare rules say fourteen days, sure, but NPAAC guidelines say that a phone request is acceptable, since a group and hold is collected and requested in the expectation of the requirement of products. I don't think it's ever gone to court...could be interesting as to whose cojones would win that fight.