Medicare 14 Day Rule: CAP Revisions – Billing News

The CAP recommended revising the 2018 Medicare Hospital Outpatient Prospective Payment System (HOPPS) proposed rule to ensure that the laboratory date of service (DOS) for all molecular testing is the date of performance rather than the date of collection, to improve the consistency with Medicare payment policy. In the September 11 letter to CMS, the CAP supports the agency’s proposed modifications to its DOS policy to allow laboratories to bill Medicare directly for …certain laboratory tests excluded from the OPPS packaging policy, which would change the current Medicare 14-day rule policy. The CAP recommended that the agency finalize an exception to the DOS policy that is not limited to Advanced Diagnostic Laboratory Tests, but also cover other molecular pathology tests. In addition, the CAP recommends revising the current rule so that the DOS for all molecular testing is the date of performance (date of final report) rather than the date of collection, to improve the consistency with Medicare policy for billing of other diagnostic services for beneficiaries.