On May 5, 2010, CMS released an interim final rule with comment period to implement several provisions of the Patient Protection

and Affordable Care Act (PPACA). One provision, Section 6406, requires the maintenance of ordering and referring documentation for at least seven years from the date of the order, referral, certification, or service for services identified as being at high risk for waste and abuse, including Medicare-covered home health, laboratory, imaging, DMEPOS, and specialist services. These documentation maintenance requirements become effective July 6, 2010, and are applicable not only to the providers and suppliers that order or make referrals for these items and services, but also to the providers and suppliers that furnish the covered items or services. Donna J. Senft and Lisa D. Stevenson discuss.