Impact on CMS reimbursement of ADLTs and Molecular Pathology testing during the 14 days following a hospital stay.
Recently it was announced that CMS will exercise enforcement discretion until January 2, 2019, for the laboratory date of service (DOS) exception policy for ADLTs and molecular pathology tests excluded from Hospital Outpatient Prospective Payment System (OPPS) packaging policy.
If you are a performing laboratory prepared to bill Medicare directly for ADLTs and molecular pathology tests subject to the new laboratory DOS exception, this enforcement discretion period does not prevent you from doing so before January 2, 2019. However, in no case should both the hospital and the performing laboratory bill for the same test for the same beneficiary.
Labs that have billed tests under the DOS exception and experienced denials, including where Medicare is secondary, may want to contact their Medicare Administrative Contractor (MAC) for further direction on these claims.
The CMS Laboratory Date of Service Policy can be found here.
For a brief overview of the Medicare Hospital Outpatient Prospective Payment System (OPPS) and revisions for 2018, you can check out this blog post.