Compliance Corner

Our hospital is taking a conservative view/interpretation of a coding service’s comment, insisting on receiving “narratives only” diagnosis information from physicians submitting orders for our outreach program. Our systems cannot handle narrative diagnosis information. What are the requirements for physicians submitting diagnosis information for laboratory services? There is a requirement that physicians include diagnosis information to support the medical necessity of all tests they order. That information may be in the form of a narrative or an ICD-9 code. There is no regulatory requirement that a physician submit narrative information only on its requests for laboratory services. They may submit either a narrative or an ICD-9 code. If the diagnosis information is incomplete or the ICD-9 code submitted is not specific enough, the lab must call the physician’s office for the correct information and document the call. Labs must maintain documentation of the source for all of the diagnosis information they include on their claims (See CMS Internet Only Manuals, Chapter 16, Section 120.1 Negotiated Rulemaking Implementation).