CERT Program Physician Signatures

March 30, 2009 CMS issued the following Joint Signature Memorandum (JSM) (JSM/TDL-09225, 03-26-09):

Recently the Department of Health and Human Services’ Office of Inspector General (OIG) conducted an evaluation of the Comprehensive Error Rate Testing (CERT) Review Contractor. As a result of this OIG review, we have concluded that the provision in the Program Integrity Manual (PIM) that has come to be known as the “clinical review judgment” provision is confusing and contradicts itself in parts. This confusion has created different interpretations of when it is appropriate for Contractor Review Staff to use clinical review judgment.

The JSM (Joint Signature Memorandum) is intended to clarify clinical review judgment. When the contactor or CERT requests an order to show medical necessity for services, including diagnostic tests, one of the following should be provided:

• The office notes where the ordering physician documented which services were to be provided
• The lab requisition signed and dated by the ordering physician

Thus, while the lab request itself does not have to have a signature, there must be a signature in at least one of the two places – either on the office note in which the intent to order the test was documented, or on the requisition or lab order slip.

Source: https://www.cgsmedicare.com/