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This new laboratory DOS policy will enable laboratories performing ADLTs and molecular pathology tests excluded from the OPPS packaging policy to bill Medicare directly for those tests, instead of requiring them to seek payment from the hospital outpatient department.

In fact, for molecular pathology tests and ADLTs meeting the above requirements, the DOS bill for these tests unless they perform them.

Stakeholders expressed concerns about the current DOS policy because it requires hospitals to bill for tests they did not perform and that may have no relationship to or bearing on treatment received by the patient while in the hospital and it creates billing difficulties for the hospital.

CMS agreed with these concerns and modified the date of service rule for hospital outpatients for molecular pathology tests and advanced diagnostic laboratory tests (ADLTs) that are not packaged under OPPS.

Drug administration services have, up until this year, escaped the packaging concept as CMS examined various alternative payment policies for drug administration, including the associated drug administration add-on codes.• The physician orders the test following the date of a hospital outpatient’s discharge from the hospital outpatient department • The specimen was collected from a hospital outpatient during an outpatient encounter • It would be medically inappropriate to have collected the sample from the hospital outpatient other than during the hospital outpatient encounter • The results of the test do not guide treatment provided during the hospital outpatient encounter • The test was reasonable and medically necessary for the treatment of an illness This revision now enables labs performing specific molecular pathology tests to bill Medicare directly instead of seeking reimbursement from the hospital.It is important to note the following exceptions to this laboratory DOS change: 1.The below PDF includes a comprehensive list of all molecular tests that are exempt from the 14 day DOS rule. The days are not too hot or too cold, so it is the perfect season to spend some time outdoors.

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