Reminder: Physician Orders Required for Diagnostic Services
WPS Medicare continues to see Comprehensive Error Rate Testing (CERT) errors attributed to the lack of physician orders for diagnostic tests. According to the Centers for Medicare & Medicaid Services (CMS) Publication 100-2, Ch.15, Sect.80.6.1, "All diagnostic x-ray tests, diagnostic laboratory tests, and other diagnostic tests must be ordered by the physician who is treating the beneficiary. Tests not ordered by the physician who is treating the beneficiary are not reasonable and necessary."
An "order" is a communication from the treating physician/practitioner requesting that a diagnostic test be performed for a beneficiary. An order may be delivered via the following forms of communication:
- A written document signed by the treating physician/practitioner, which is hand-delivered, mailed, or faxed to the testing facility
- A telephone call by the treating physician/practitioner or his/her office to the testing facility (If the order is communicated via telephone, both the treating physician/practitioner or his/her office, and the testing facility must document the telephone call in their respective copies of the beneficiary's medical records)
- An electronic mail by the treating physician/practitioner or his/her office to the testing facility.
A signed physician's order is not required for clinical diagnostic tests paid on the basis of the clinical laboratory fee schedule, the physician fee schedule, or for physician pathology services. However, the physician must clearly document, in the medical record (e.g., in a progress note completed by the requesting physician) his or her intent that the test be performed. To avoid unnecessary denials, or multiple records requests, WPS Medicare recommends that physicians provide an electronic or hand written signature on all orders.
When responding to Medicare requests for records to support diagnostic services, the billing provider is responsible for submission of the physician order or progress notes showing physician intent for the service (s) to be rendered. In addition, the order or progress note must contain a valid electronic or hand written signature of the requesting provider. An unsigned requisition is not valid evidence of physician intent per Medicare guidelines, and, therefore, does not support the medical necessity of the services. Failure to comply with these requirements will result in recoupment of the Medicare payment for the service(s) rendered.
Page Last Updated: Thursday, 15-Jul-2010 09:55:25 CDT


