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Noncompliant prescriptions

Compliance Monitor, March 10, 2006

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Q: I have a few questions related to noncompliant scripts. Do lab requisitions printed with physicians' names also need physician signatures?

What are the components of a compliant script?

Also, a CMS transmittal allows facilities to verbally communicate a diagnosis, could allowing clerical staff to give and receive diagnosis increase risk.

A: Being compliant with any aspect of healthcare, whether it's ordering of test, charging for services, billing of claims, etc., should be your top priority in today's world. A compliant script should contain patient name, date, test ordered, diagnosis, and physician signature.

According to Medicare's conditions of participation regulations a physician order must be "signed". It does not go on to define or state, that "signed" means, physically hand written with ink, stamped, electronically signed etc. An electronic signature may take the place of actual written signatures but have to be actually entered by the physician.

A lab requisitions with printed names does not constitute a signature. A number of associations and organizations also weigh in on this topic, among them CMS regulations, Joint Commission on the Accreditation of Healthcare Organizations (JCAHO) requirements, and even Clinical Laboratory Improvement Amendments for laboratories.

JCAHO actually requires all requests for lab tests to be made in writing or through electronic means; oral request are permitted ONLY if the laboratory obtains written authorization for testing in accordance within its own policy, but within 30 days. Your state laws usually require that ordering laboratory tests and the prescription of biologics, drugs, etc. (which usually includes "therapeutic" phlebotomy and blood transfusion) require a physician's order, or that of an appropriately credentialed non-physician practitioner for some laboratory tests. Check your state laws for what constitutes a legitimate physician's order and whether it needs to be written.

REFERENCES: 1) Department of Health and Human Services, Health Care Financing Administration. Clinical laboratory improvement amendments of 1988; final rule. Federal Register. 1992(Feb 28):7162 [42CFR493.1105]; Another member wrote that in her hospital, ALL ORDERS (verbal or otherwise) must be signed by the ordering physician within 24 hours. However, in certain areas, they do have verified electronic signatures which take the place of actual written signatures but have to be actually entered by the physician (not a PA, secretary, etc.). In New York State, it does. Thanks to Kathi L Austin, CPC, CPC-H, CCP, Corporate Director Revenue Integrity at the Sisters of Mercy Health System in St. Louis for answering this question.

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