Corporate Compliance

Q: Is there an expiration date on standing orders? For example, a physician can order a prothrombin for a year. If he/she writes the order 07/24/04 how long before it expires and we need a new one?

Compliance Monitor, July 30, 2004

There is no national policy that dictates the expiration date of standing orders such as these. However, most providers require that they be renewed at least annually, and in some cases as frequently as every three months.

The Survey Procedures and Interpretive Guidelines for Laboratories as promulgated under CLIA, in section D5301 (§493.1241), state that the "Use of standing orders should be clearly defined in written policy, describing which tests may be covered by standing orders and at what interval standing orders should be reconfirmed."

However, they make no suggestion as to what that interval should be, leaving this instead to each lab to decide.

When deciding what is reasonable, a time period of up to one year seems reasonable for most orders (shorter periods may be appropriate for some types of tests or treatments). The one-year rule of thumb is the prescription limit under most state laws, and is also referenced in other Medicare policies, such as the time limit before an Advance Beneficiary Notice (ABN) expires, and the OIG Lab Compliance Guidance. Providers should also be sure to check for any state laws addressing standing orders and their expiration.

This question was answered by Francesca Hartop, COO, Yost Engineering, Inc. in Portsmouh, OH.

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