Although many professional groups and organizations lobbied against the signature requirement, CMS is implementing this provision as part of the CY 2011 MPFS. Starting January 1, 2011, the ordering physician must sign all written or paper requisitions for laboratory tests and services. Clinical laboratories will have to scramble to revise requisitions to include a signature line for the ordering physician.
However, those labs that receive test orders via electronic or web-based interfaces should not be affected by the signature requirement included in the 2011 MPFS. In the comments to the proposed 2011 MPFS, CMS states,
"Our proposed policy does not concern electronic or telephonic requests, because we do not consider these types of requests to be requisitions. As we discussed previously, a requisition is the actual paperwork, such as a form, that is provided to a clinical diagnostic laboratory that identifies the test or tests to be performed for a patient.
These are the latest updates as of December 17, 2010. We anticipate the usual flurry of activity following the holidays and will keep our subscribers updated. Happy holidays!