Laboratory Question for the Week of February 24, 2025

Question:

What are the key compliance requirements and challenges associated with standing orders for laboratory services under Medicare regulations?

Answer:

The OIG’s Compliance Program Guidance for Clinical Laboratories (August 1998) notes that standing orders, also referred to as recurring orders, need fixed term limits (i.e., start and stop dates). All recurring orders are to be reviewed at least annually (some laboratories have set six months for the review). A recommended practice is to develop a recurring order form instead of using a prescription pad or outpatient requisition. In addition to the start and stop date, a recurring order should stipulate the frequency for testing. In 2007, several intermediaries issued statements regarding the non-coverage status of standing orders for procedures. The statements were followed by a transmittal issued by CMS in late 2007, which caused a great deal of concern in the laboratory industry when this information was interpreted to mean that the recurring orders utilized by laboratories would be affected. This language is not new to the Medicare program; it is the same information that was previously included in Transmittal AB-00-108 (CR #1362) issued to intermediaries and carriers on December 1, 2000, which stated, “A standing order is not usually acceptable documentation for a covered laboratory service.” To clarify the above, the standing order is an order or facility protocol that is in place to direct testing over a period of time that is non-specific in regard to the patient’s sign or symptom. This type of order is commonly encountered in the area of pre-admit testing for invasive radiology or surgical encounters. Note that protocols are not accepted by Medicare as orders. One example is when an imaging department requires BUN/creatinine for all patients over the age of 50 who are about to be administered contrast material. Another example is when the coagulation department receives a pre-operative request for PT/aPTT for all patients regardless of age or health history. The standing order is distinctly different from the recurring order, which is submitted by the treating physician and is specific to the diagnosis or sign/symptom exhibited by a patient. The confusion seems to be due to the way in which CMS and other government entities use the terms “standing order” and “recurring order” interchangeably.

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