Effective January 1, 2018, CMS created an Exception to its 14 Day Rule for hospital outpatients receiving molecular pathology and advanced diagnostic lab tests that enabled providers performing the tests to bill Medicare directly for the first time. Previously, payment for the testing was included in the hospital’s reimbursement and the lab would have to seek its portion from the facility. For the most part this was due to Medicare’s Date of Service (DOS) policy which states that, in general, the pathology DOS is the date the specimen was obtained. For many molpath tests and ADLTs it’s common for the specimen to have been collected while the patient was hospital outpatient status and used later for testing after the patient has been discharged. Under the rules of the Exception, as long as the conditions are met, the DOS in this scenario for the test would be the date it was performed, NOT the date the specimen was collected. Visit CMS’s webpage, Laboratory Date of Service Policy, for the criteria and CPT codes included in this policy exception. APS articles on this topic can be reviewed at our website on the White Papers tab.
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