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January 30, 2013 – Revised: 01.21.15

Radiology Services: Treating Physician/Practitioner Order Required

Referring physicians are required by law to provide diagnostic information to testing entities at the time services are ordered. In addition, the law requires that all diagnostic tests be ordered by the physician who is treating the beneficiary (42 CFR 410.32). (Exception: an interpreting physician may order a diagnostic mammogram based on the results of a screening mammogram (42 CFR 410.32a(1)).

An "order," for Medicare purposes, is defined as "a communication from the treating physician/practitioner requesting that a diagnostic test be performed for a beneficiary" (CMS Medicare Claims Processing Manual (Pub. 100-04), chapter 23, section 10.1.2External PDF). An order may be:

  • A written document, signed by the treating physician/practitioner, which is hand-delivered, mailed, or faxed to the testing facility;
  • A telephone call from the treating physician/practitioner or his/her office to the testing facility; or
  • An e-mail from the treating physician/practitioner or his/her office to the testing facility.

If the diagnostic test was performed based on a telephone call from the treating physician/practitioner or his/her office, CGS expects that the testing entity will document this verbal order in the patient's medical records.

Documenting Orders

You must provide documentation of the treating physician's order, along with other appropriate documentation to support the medical necessity of the service, upon request from CGS or other Medicare review contractor (including the Comprehensive Error Rate Testing (CERT) contractor and Recovery Audit Contractor (RAC)). If you accept an order for services, and the referring physician or practitioner has not provided information regarding the diagnosis or an acceptable order for the services, you are putting your payments at risk. CGS looks to the provider that submits the claim for supporting documentation.

Signatures are also required in medical records. Signatures may be hand-written or electronic, must be legible, and should include the credentials of the person signing the records. For more information about signature requirements for Medicare purposes, please refer to the following resources:

Other references:

Reviewed: 12.09.22

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