In the 2011 Medicare Physician Fee Schedule Final Rule, published in the November 29, 2010, edition of the Federal Register, the Centers for Medicare & Medicaid Services ("CMS") stated its intention to begin requiring physician signatures on all laboratory requisition forms reimbursable by Medicare beginning on January 1, 2011. Laboratory requisition forms are those documents provided to a clinical diagnostic laboratory that identify the test or tests to be performed, but they are not considered to be physician orders that heretofore required a physician's signature.

While many physicians and clinical laboratories grumbled about the new requirement, it was the nursing facility industry that most actively—and successfully—pleaded its case to CMS. According tothe American Health Care Association ("AHCA"), CMS has agreed to withdraw the new signature requirements for laboratory requisitions in the case of nursing facility residents.