CMS to Rescind Physician Signature Requirement
This notice was sent by the CAP today. Congratulations on their efforts on behalf of the laboratory community in eliminating this potentially onerous requirement.
Feb. 21-CMS officials are planning to withdraw the provision of the Physician Fee Schedule (PFS) Final rule 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). Originally slated to take effect on Jan. 1, the requirement had already been delayed through the first quarter of 2011.
CMS's decision to rescind the requirement comes days after the agency's Deputy Administrator Jonathan Blum acknowledged concerns expressed by physician and laboratory stakeholders about the potential negative impact of this new requirement. At an AMA-convened meeting on Feb. 9, which was attended by the CAP, he also acknowledged that agency officials were taking a "fresh look" at the requirement, which was intended to streamline the auditing process.
Recent Medi-Cal/ Department of Justice Fraud Actions Re Pap Smear Billing
A member pathology group reported that yesterday they were served with a search warrant by no less then 15 Department of Justice agents asking for records related to billing for pap smears. They were informed that there were allegations of fraud in the billing of liquid based pap smears and CPT 88175, screening by automated system and manual rescreeing, under physician supervision. It appears that DOJ was informed that this code would require the patient to return for a second pap smear, i.e. rescreening. Since they had interviewed some of the patients who had been the recipients of that service and been informed that only one specimen collection occurred the conclusion was that it represented fraudulent billing. There obviously is a major misunderstanding on that code and what it represents.
The CSP has contacted the DHCS in an effort to find out the source of this conclusion, educate them on how this code is billed, and the nature of automated screening with liquid based specimens. If any other laboratory has this experience please contact the CSP.