Pathology/Lab Coding Alert

You shouldn't need to meet the requirement in the meantime.

While you wait for CMS to officially rescind the rule requiring physician signatures on clinical diagnostic laboratory test requisitions, your Medicare contractor shouldn't be enforcing the rule.

That's according to a memorandum from the Medicare Contractor Management Group director to all Fiscal Intermediaries (FIs), Carriers, and Part A/Part B Medicare Administrative Contractors (AB/MACs).

Recall the Signature-Requirement Back Story

CMS delayed implementation and unofficially announced its intention to rescind the rule by April 1 -- which you read about in Pathology/Lab Coding Alert Vol. 12 No. 5, "Look for Lab Requisition Physician Signature Reprieve." The agency ran into difficulties meeting that deadline, however.

Here's why: To formally rescind the rule, CMS needs to go through the regular administrative process, which means issuing a notice or rule and requesting comment. That process may not conclude until the end of 2011, according to CMS.

Keep Current Standard

The Medicare Benefit Policy Manual (CMS IOM Pub. 100- 02, chapter 15, §80.6.1) states that no signature is required "for clinical diagnostic tests paid on the basis of the clinical laboratory fee schedule, the physician fee schedule, or for physician pathology services."

Do this: "By stating that the agency won't implement the physician signature requirement, CMS reverts to the standard put forth in the Benefit Policy Manual," says Larry Small, MS, MT(ASCP), CEO and Managing Partner of Lab/Path Consulting in Tierra Verde, Fla.