Practice Management

 View Only
Back to discussions
Expand all | Collapse all

Standing Order Regulations for Imaging Centers

  • 1.  Standing Order Regulations for Imaging Centers

    Posted 02-07-2018 20:22
    I wanted to know if anyone had a good site where I could do research on accepting standing orders at our imaging sites for all modalities. Does anyone accept standing orders, if so is it just for screening mammograms for example or any exam? Any help is greatly appreciated, thank you.

    ------------------------------
    Diane Ramirez
    Business Office Manager
    Radiology and Imaging of South Texas LLP
    Corpus Christi TX
    361-853-4503
    ------------------------------


  • 2.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 09:23
    I can't think of any example of a study where it would be acceptable to use "standing orders" for an exam that normally requires an order.  Certainly for Medicare, every order has to be documented and signed in the ordering practitioners medical record.  A good place to start with respect to Medicare rules is section 80.6 here:  https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c15.PDF
    There are some additional constraints if you're an IDTF.

    I'm sure other payor policies also discuss orders, typically in the context of medical necessity.

    Since screening mammograms don't require an order, it doesn't make much difference whether you have an order, standing or otherwise, except that it may obligate the ordering practitioner to follow up on results.

    ------------------------------
    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
    ------------------------------

    Original Message


  • 3.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 14:32
      |   view attached

    Diane,

    Here is a memo I wrote several months ago when some at the hospital were agitating for use of standing orders to avoid having to get individual signed orders.   Several years ago CMS approved the use of Standing Orders in order to expedite care, BUT, they still explicitly require the ordering physician to sign off on each order upon its use after the fact.  That is not how most want to use them – they want to avoid having to get it signed.  CMS makes it clear you ALWAYS need order authenticated, even after the fact when they are part of a "standing order" (or protocol or order set).  My memo includes citations from source documents. 

    MBohl

     

     




    Attachment(s)

    pdf
    Protocol Issue v2.pdf   359 KB 1 version
    Original Message


  • 4.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 14:37
    Technically there's no standing order.  CMS views each order separately so the "authentication" is really a separate order for Medicare purposes, and you have to get it every time to be safe.

    Wayne K. Baldwin
    805-879-7577



    Original Message


  • 5.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 16:29

    CMS specifically recognized and approved the use of Standing Orders (also referred to as Protocols and Order Sets) in the May, 2012 Hospital Conditions of Participation Final Rule.  The rule makes great reading.  I encourage you to download a copy and read it.  In this rule, CMS went to great length describing how they are to be used.  HOWEVER, even when they are used, CMS still requires each specific standing "order" to be retrospectively signed by the ordering physician "promptly" in the medical record.  They had proposed a 48 hour signing requirement, but loosened the language to read "promptly" in the Final Rule.

    Having said that, this is not how those that want to use Standing Orders want to use them.  They want to avoid getting the order signed.  They can't do that – it still must be signed and dated.

     

    MB

     




    Original Message


  • 6.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 16:33
    Mike

    Perhaps an academic question, but aren't the hospital conditions of participation only applicable to hospital billing?  I would be surprised if they apply in a physician office or IDTF, or even to a radiologist billing for professional component in a hospital setting.

    ------------------------------
    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
    ------------------------------

    Original Message


  • 7.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 18:10

    David,

    I agree, that is an  important distinction I failed to mention.  We operate 3 JV'd imaging centers operating as hosp opt departments, so the rules would apply to us.  If I was a physician-based or IDTF I would not use standing orders with seeking a legal opinion first. 

    MB

     




    Original Message


  • 8.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-09-2018 09:29
    Good points by others on standing orders. Practically, you need to take care -- rightly or wrongly, payors (federal or private) hate them and will stretch to allege that they are improper.

    See, eg, https://www.justice.gov/usao-vt/pr/dominion-diagnostics-pays-815000-united-states-and-state-vermont-resolve-allegations.

    Standing orders are sometimes workable, but they have to be delicately tailored with an eye towards future defensibility.

    Sent from Nine. Excuse voice transcription errors.

     


    https://www.dropbox.com/s/rsvv2kfg08ifhu0/HLP_logo.tif?raw=1


    Clinton Mikel

    Partner

    The Health Law Partners, P.C.

    p:

    (248) 996-8510  m: (313) 600-8587

    f:

    (248) 996-8525

    a:

    32000 Northwestern Hwy., #240, Farmington Hills, MI 48334

    w:

    www.thehlp.com   e:  cmikel@thehlp.com

    http://cdn2.hubspot.net/hubfs/184235/dev_images/signature_app/linkedin_sig.png


     

    The Health Law Partners, P.C. (HLP), is a Michigan professional corporation. The HLP operates additional offices in New York as "The Greenberg, Dresevic, Iwrey, Kalmowitz & Pendleton Law Group".

    *********************************************************************

    CONFIDENTIAL: This electronic message and all contents contain information which may be privileged, confidential or otherwise protected from use/disclosure. Some information, such as health information, may be further protected by state and federal laws, which may impose liability for the recipient's improper use, disclosure, or retention of the information. The information is for the addressee only. If you are not the addressee, any disclosure, copy, retention, distribution or use of the contents of this message is prohibited. If you have received this electronic message in error, please notify HLP immediately by calling (248) 996-8510, or emailing us atpartners@thehlp.com, and destroy the original communication and all copies thereof.








    Original Message


  • 9.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-12-2018 21:49
    Thank you everyone, all the comments and links have been very beneficial. 

    Appreciate it!

    ------------------------------
    Diane Ramirez
    Business Office Manager
    Radiology and Imaging of South Texas LLP
    Corpus Christi TX
    361-853-4503
    ------------------------------

    Original Message


  • 10.  RE: Standing Order Regulations for Imaging Centers

    Posted 02-08-2018 13:23
    Medicare Benefit Policy Manual §80.6.1 - Medicare doesn't approve of standing orders.  You can have conditional order, but read the manual.  Here's some relevant excerpts form this section of the manual with some editorial comments:

     
    Order Defined.  "An "order" is a communication from the treating physician/practitioner requesting that a diagnostic test be performed for a beneficiary. The order may conditionally request an additional diagnostic test for a particular beneficiary if the result of the initial diagnostic test ordered yields to a certain value determined by the treating physician/practitioner (e.g., if test X is negative, then perform test Y). An order may be delivered via the following forms of communication:
     
    • A written document signed by the treating physician/practitioner, which is hand-delivered, mailed, or faxed to the testing facility; NOTE: No signature is required on orders for clinical diagnostic tests paid on the basis of the clinical laboratory fee schedule, the physician fee schedule, or for physician pathology services;
     
    • A telephone call by the treating physician/practitioner or his/her office to the testing facility; and
     
    • An electronic mail by the treating physician/practitioner or his/her office to the testing facility."
     [Email must of course be encrypted and secure under HIPAA]
    <en-clipboard></en-clipboard>


    Trusted to provide expert and caring radiology service for over 50 years

    Wayne Baldwin
    CEO
    (805) 879-7577

    CONFIDENTIALITY NOTICE: This electronic mail  may contain information that is confidential, privileged, proprietary, or otherwise legally exempt from disclosure. If you are not the intended recipient, you are hereby notified that you are not authorized to read, print, retain, copy or disseminate this message, any part of it, or any attachments. If you have received this message in error, please delete this message and any attachments from your system without reading the content and notify the sender immediately of the inadvertent transmission. There is no intent on the part of the sender to waive any privilege that may attach to this communication. Thank you for your cooperation.



    Original Message


  • 11.  RE: Standing Order Regulations for Imaging Centers

    Posted 03-04-2019 10:30
    Good afternoon, 

            Is it normal practice for Radiology Technicians to obtain signs and symptoms, chronic conditions, and medication usage information from patients? I am seeing final rad doc notes with information that was never on the referring physicians order (specifically the indications area).​ I have read articles that state this is acceptable, but I have also read articles that state ALL information must be provided by the referring provider. I am finding the differences between the history sheet, referring physicians orders and final note greatly impacts medical necessity. What are the rules, and how must the changes be documented to not raise a red flag to auditors or Medicare?

    ------------------------------
    Jennifer Nicholson
    Compliance Coordinator
    Radiology Regional Center
    Fort Myers FL
    239-936-2316
    ------------------------------

    Original Message


  • 12.  RE: Standing Order Regulations for Imaging Centers

    Posted 03-04-2019 12:12

    Jennifer – What you outline is a common practice. The techs can take notes in their evaluation of the patient and include those in the information available to the radiologist as they provide their interpretation. Most RIS, EHR systems have a Tech Notes or something similar area for this information so that it does become part of the patient record.... Hope that helps...

     

    Keith E. Chew, MHA, CMPE, FRBMA
    C | 217-971-5293  

    18 Hawks Nest | Chatham, Illinois     62629

     




    Original Message


  • 13.  RE: Standing Order Regulations for Imaging Centers

    Posted 03-04-2019 12:47

    Hi Jennifer,

     

    The important part is for the radiologist to dictate in his/her report the source of the information (tech, patient, family member).

     

    Barbara F. Rubel MBA, FRBMA

    Senior VP, Marketing & Client Services

     

    brubel@msnllc.com

    904-657-2038 (Office) | 770-823-3597 (Cell)
    MSNLLC.com

     




    Original Message


Related Content