Office of Inspector General and laboratory standing orders

In a previous blog entry, I discussed the issue of troponin test intervals and how many of the problems around test intervals are ultimately related to a lack of laboratory input in the creation and maintenance of order sets leading to inefficient and improper test utilization.  This issue not only includes order sets but also standing orders, protocols, physician “favorites”, etc.  In my experience, even if a laboratory asks to be included in creation and maintenance of these tools, we are often simply brushed aside or otherwise denied a seat at the table.  What else can we do to justify our inclusion in order set committees that also create protocols, standing orders, etc?  One powerful argument is that we are required to participate in the creation of “standing orders” per the OIG. In the Publication of OIG Compliance Program Guidance for Clinical Laboratories, the OIG clearly states that laboratories are required to periodically monitor standing orders to ensure there are no “abusive practices” (page 45081, section 4).  This document was written in 1998 so it’s a little dated – if rewritten today it would include order sets, protocols, favorites, etc.  But none the less even as written I believe this document helps provide regulatory justification for laboratory to review standing orders and by extension in today’s world of the EMR, order sets, protocols, and favorites.  If you have a few minutes read through the OIG document as it has some very interesting requirements and suggestions around laboratory utilization that I’ll also cover in future posts.

https://oig.hhs.gov/documents/compliance-guidance/806/cpglab.pdf