Laboratory Services: Submitting Requested Documentation to the CERT

Published 02/08/2018

Railroad Medicare is seeing an increasing volume in laboratory services claims selected by the Comprehensive Error Rate Testing (CERT) contractor for review. The majority of improper payments for laboratory services identified by the CERT are due to insufficient documentation. The following guidelines may be used to assist you in your response to the CERT’s request.

Documentation Requirements

  • The treating physician must order all diagnostic tests. The treating physician performs a consultation or treats a beneficiary for a specific medical problem and uses the laboratory results in the management of the beneficiary's condition. Tests not ordered by the treating physician are not considered reasonable and necessary.
  • When completing progress notes, the physician should clearly indicate each specific test to be performed
  • Documentation in the patient’s medical record must support the medical necessity for ordering the service(s), per Medicare regulations. These include:
    • Progress notes or office notes;
    • Physician order/intent to order;
    • Laboratory results; 
    • Attestation/signature log for illegible signature(s)

Additional Guidance

  • When you receive a request for records, they may be housed at another location (for example, a nursing facility, hospital, or referring physician office). If the requested documentation is located at another facility, it is the billing provider’s responsibility to obtain the medical records, regardless of where the records are housed. The CERT contractor cannot be referred to a third party to obtain medical records.
  • Submit a signature log or attestation with requested documentation if the provider signature is illegible or if progress notes supporting intent are missing the provider’s signature. Attestation statements are not acceptable for unsigned physician orders/requisitions.


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