CMS Delays Requisition Signature Requirement

Many of you may be aware that one element of the Medicare Physician Fee Schedule for 2011 was a new requirement regarding physician signature for all paper lab requisition forms. The CSP had been in contact with the CAP to express our concerns with the burden this would impose on clinical laboratories. Though it would not have impacted electronic requisitions, it would have been impossible to implement for those labs using paper forms. This effort to spur conversion to electronic forms and EMR is laudable but not practical on such short notice. Congratulations to CAP for pushing for this delay, which should be at least until March 1, 2011 and hopefully beyond that date.     

Dec. 21-The Centers for Medicare & Medicaid Services (CMS) announced today that it will delay implementation of the Physician Fee Schedule (PFS) Final rule provision requiring a physician's or qualified non-physician practitioner's (NPP) signature on all requisitions for tests paid on the Clinical Laboratory Fee Schedule (CLFS) that was scheduled to go into effect on Jan. 1, 2011.

At this time CMS has not turned on the automated edits that would deny claims for services that were ordered or referred by a physician or other eligible professional simply for lack of an approved file in PECOS.  CMS is working diligently to resolve backlog and other systems issues and will provide ample advance notice to the provider and beneficiary communities before CMS begins any such automatic denials.  While there are some rumors that the edits will be turned on in January, we want to reiterate that CMS has not announced any date (January 3 or otherwise) as to when ordering/referring edits will be turned on.

Physicians or other eligible professionals not currently enrolled in PECOS should take the initiative to enroll sooner rather than later.   There are three ways to verify that you have an enrollment record in PECOS:

• Check the Ordering Referring Report on the CMS website, available here.  If you are listed on that report, you have a current enrollment record in PECOS.

• Use Internet-based PECOS to look for your PECOS enrollment record, available here.  If no record is displayed, you do not have an enrollment record in PECOS.

• Contact your designated Medicare enrollment contractor and ask if you have an enrollment record in PECOS.  Visit www.cms.gov/MedicareProviderSupEnroll for the "Medicare Fee-For-Service Contact Information" list (in the "Downloads" section).

If you are not yet in PECOS, the best way to submit your application is through internet-based PECOS.  For more information, click here.

The Centers for Medicare & Medicaid Services (CMS) would like to remind Medicare Fee-For-Service physicians, providers and suppliers submitting claims to Medicare for payment, as a result of the Patient Protection and Affordable Care Act (PPACA), effective immediately, all claims for services furnished on or after Jan 1, 2010, must be filed with your Medicare contractor no later than one calendar year (12 months) from the date of service - or Medicare will deny them.

If you have Medicare Fee-For-Service claims with service dates from Oct 1, 2009, through Dec 31, 2009, those claims MUST be filed by Dec 31, 2010, or Medicare will deny them. Claims with service dates from Jan 1, 2009, to Oct 1, 2009, keep their original Dec 31, 2010 deadline for filing.

In general, the start date for determining the 1-year timely filing period is the date of service or "From" date on the claim.  For institutional claims that include span dates of service (i.e., a "From" and "Through" date on the claim), the "Through" date on the claim is used for determining the date of service for claims filing timeliness.  For claims submitted by physicians and other suppliers that include span dates of service, the line item "From" date is used for determining the date of service for claims filing timeliness.