ATTENTION AAB AND NILA MEMBERS: 

CMS Wants To Require Physician Signatures On All Laboratory Requisitions! 

We want to bring to your attention a section of the Calendar Year 2011 Physician Fee Schedule CMS Proposed Rule that was released on June 25, 2010.  The proposed rule includes a section regarding the Part B Clinical Laboratory Fee Schedule (CLFS) and physician signatures on requisitions for clinical diagnostic laboratory tests.  In order to clarify some confusion between "orders" and "requisitions," CMS is proposing to require a physician's, or non-qualified physician practitioner's, signature on all requisitions for clinical diagnostic laboratory tests paid through the CLFS.  AAB and NILA do not support this proposal! 

As you know, AAB/NILA is a member of the Clinical Laboratory Coalition (CLC), a coalition that includes 10 major laboratory associations. AAB/NILA brought this issue to the attention of the CLC, and all members of the CLC have voiced opposition to CMS’s proposal. During the past two weeks the members of the CLC worked together to draft comments objecting to this proposal. Click here to view/download those draft comments. Click here to view/download a copy of the pages from the proposed rule specifically relating to physician signatures on clinical laboratory requisitions. 

We hope that you will take a few minutes to review the comments, and that you will forward your own, personalized comments from your laboratory.  It would also be helpful to have your employees forward letters of their own.  The more comments that CMS receives in opposition to this proposal, the better our chances are at keeping it from moving forward.  Comments are due to CMS by 5:00 PM on August 24, 2010. 

Below are the instructions for submitting comments. Please follow them closely to ensure that your comments are received and registered. If you have any questions, contact the AAB/NILA office directly. 

Comment Submission Instructions (from CMS): 

DATE: To be assured consideration, comments must be received at one of the addresses provided below, no later than 5 p.m. on August 24, 2010.  

ADDRESSES: In commenting, please refer to file code CMS–1503–P. Because of staff and resource limitations, we cannot accept comments by facsimile (FAX) transmission. You may submit comments in one of the following ways (please choose only one of the ways listed): 

1. Electronically. You may submit electronic comments on this regulation to http://www.regulations.gov. Follow the instructions for ‘‘submitting a comment.’’
    
2. By regular mail. You may mail written comments to the following address only:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1503–P
P.O. Box 8013, Baltimore, MD 21244–8013. 

Please allow sufficient time for mailed comments to be received before the close of the comment period. 

3. By express or overnight mail. You may send written comments to the following address only:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1503–P
Mail Stop C4–26–05
7500 Security Boulevard
Baltimore, MD 21244–1850