Medicare Compliance & Reimbursement

In an attempt to clear up confusion about who can request a diagnostic test, a recent transmittal outlining the requirements has unfortunately had the opposite effect, leaving practices scratching their heads.

Several years ago, CMS altered its rules governing physicians' signatures for requiring diagnostic tests. The change, however, never made its way into Medicare's Internet Only Manual.

To streamline its advice, CMS issued Transmittal 94 on Aug. 29. The transmittal covers the differences between "treating physicians" and "ordering physicians," and discusses when you must have a physician's signature on file and when you don't need one.

CMS also clarified the long-confusing term "physician order."

"Many practices consider an order a written piece of paper, but that isn't always the case," says Heather Corcoran with CGH Billing in Louisville, KY.

Reality: A physician order is "a communication from the treating physician/practitioner requesting that a diagnostic test be performed for a beneficiary," the transmittal says.

The order can be hand-delivered, mailed, or faxed to the testing facility if the physician has written it down. However, CMS notes that the order can also be communicated via telephone or email.

"If you give a testing order on the phone, both the ordering and treating physicians have to make sure to document it in the patient's medical record," says Jay Neal, an Atlanta-based coding consultant.

Signature debate: Although many coders dispute this fact, CMS clearly says in its transmittal that the physician order need not be signed; however, the physician must document his intent that the test be performed.

To read the transmittal, go online to www.cms.hhs.gov/transmittals/downloads/R94BP.pdf.