On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) indicated it intends on changing the regulation that requires certain signatures on laboratory requisitions. CMS is making this change because of concerns that physicians, non-physician practitioners (NPPs), and clinical diagnostic laboratories are having difficulties complying with the signature policy, as previously published.
The November 29, 2010, the Physician Fee Schedule (PFS) final rule adopted a policy requiring a physician’s or NPP’s signature on requisitions for clinical diagnostic laboratory tests paid on the basis of the Clinical Laboratory Fee Schedule (CLFS). In finalizing the CY 2011 PFS proposed rule, CMS stated that the Signature Policy would result in a less confusing process, would not increase the burden on physicians, and would make it easier for laboratory technicians to know whether a test is appropriately requested, thereby minimizing the laboratory’s potential compliance problems. After considering comments to the proposed signature policy, CMS noted that it was finalizing the policy without modification to require a physician’s or NPP’s signature on requisitions for clinical diagnostic laboratory tests paid under the CLFS, and that it would make the corresponding changes to its manuals.
In contrast to its initial statements, on March 31, 2011, CMS transmitted that after further input from the community, it has decided to focus on changing the signature requirements applicable to certain laboratory requisitions. To date, no regulation rescinding the PFS final rule’s signature policy has been published.