Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
documentation for 7 years from the date of billing. We
maintain that it is less burdensome for providers and
suppliers to maintain ordering and referring documentation
for 7 years from the date of service rather than requiring
providers and suppliers to maintain ordering and referring
documentation associated with the proposed provision for
10 years after the date of payment.
Comment: One commenter disagrees with increasing the
retention of ordering and referring documentation beyond
the current 7 years from the date of payment. The
commenter continued to state that the provision as proposed
may represent an additional cost for 3 years of additional
record retention.
Response: As stated above, we are establishing an
ordering and referring record retention period as 7 years
from the date of service.
Comment: One commenter believes that CMS must
understand that in virtually all cases, the only
information the laboratory receives is the laboratory
requisition submitted by the physician.
Response: We continue to believe that it is necessary
that providers and suppliers retain ordering and referring
documentation for services furnished 7 years from the date
of service. However, we understand that the supplier may
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