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Compliance actions against prescribers who do not meet the compliance threshold based on other prescriptions will commence on or after January 1, 2023

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Comment: Several commenters asked CMS to make the policy in this proposal clear to our contractors (MACs), that is, the specifics of what we included in the CY 2025 PFS proposed rule (89 FR 61739): When the patient's medical record includes a signed and dated written order or referral indicating the type of therapy needed, CMS (and our contractors) would treat the signature on the order or referral as equivalent to a signature on the plan of treatment. They additionally asked that we notify our MACs/contractors through a formal program memorandum prior to the policy becoming effective on January 1, 2025, stating that physician signature requirement for the POC certification has been a frequent targeted area for denials and oversight