CMS Rescinds Clinical Lab Requisition Physician Signature Requirement

The Centers for Medicare and Medicaid Services (CMS) will be rescinding the requirement for a physician’s signature on clinical lab requisitions for all settings, including skilled nursing facilities (SNFs).

Even prior to publication of the final rule, published on November 29, 2010 as part of the CY 2011 Final Physician Fee Schedule Rule (73 FR 73170), AHCA and other members of the Clinical Lab Coalition were fighting this issue. They were successful in obtaining a delay in implementation to March 31, 2011, since the requirement was to have been effective on January 1, 2011.

AHCA had sought withdrawal of this policy since it would be in direct contradiction to the stringent regulatory mandates regarding timely and high quality nursing facility care. Requiring a physician signature on clinical lab requisitions also would have been a complete negation of the efforts of AHCA provider members to provide the highest quality care possible.

Furthermore, in many cases, facilities would have been forced to send patients to the hospital so that clinical laboratory tests could be obtained in a timely fashion, causing totally unnecessary trips, potentially harmful transfers for patients, and increased costs to the Medicare program. AHCA was concerned that CMS had reversed its long-established position on lab tests, put in place after a lengthy negotiated rulemaking process in 2001 with broad stakeholder involvement, which established that there were alternatives to document physician intent to order a lab test besides a physician signature on the requisition, such as notation in the patient’s medical record.