Corporate Compliance

Signatures not required, but are good practice

Mammography Regulation and Reimbursement Report, April 1, 2009

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The Centers for Medicare & Medicaid Services (CMS) recently clarified its position that physician signatures are not required on orders for diagnostic tests, provided the physician clearly documents that he or she ordered the test in the medical record. The clarification came via an August 29, 2008, transmittal that replaced language inadvertently omitted from the Medicare Benefit Policy Manual. This exemption applies to all tests that meet the following criteria:

  • Paid according to clinical laboratory fee schedule
  • Paid according to the Medicare physician fee schedule
  • Paid for physician pathology services

However, experts say that just because a signature isn’t required on these tests, it doesn’t mean your facility shouldn’t get them. Although CMS may not require physician signatures on this type of diagnostic order, other insurers do, says Cheryl A. Schad, BA Ed, CPC, ACSRA, PCS, a reimbursement specialist and owner of Schad Medical Management in Mullica Hill, NJ. “It’s always better to kill two birds with one stone,” Schad says.

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