The Centers for Medicare & Medicaid Services (CMS) published a proposed rule in the Federal Register on June 30, 2011, that would retract the CMS policy requiring that requisitions for clinical diagnostic laboratory tests be signed by a physician or non-physician practitioner (NPP). This signature requirement had been scheduled to take effect on January 1, 2011, but enforcement had been postponed. This requirement and the proposed change are discussed below.

Background

Medicare regulations require that diagnostic laboratory tests and various other diagnostic tests be ordered by the physician or NPP who is treating the patient. The regulations also mandate that the ordering physician or NPP maintain documentation of medical necessity in the patient’s medical record and that the laboratory or other entity submitting the claim for the test maintain the documentation that it received from the ordering physician or NPP.