How to Apply for CMS Date of Service Demo

The CMS Date of Service Demo is in the forefront for laboratories especially those with high complexity tests often with built-in algorithms. The goal of the demo is to allow for separate payment to laboratories with these complex tests billed with a date of service that would under standard Medicare rules be bundled into the payment to the hospital or critical access hospital (CAH). The demo will be conducted for 2 years or $100M of expenditure, whichever comes first. It is intended to result in a report to Congress with an assessment of the impact on access to care, quality of care, health outcomes and expenditures. Unfortunately, it has also been repurposed as a pricing exercise during which new pricing will be assigned to six new G code buckets as well as to the 36 existng cpt codes that are eligible for the demo.

One question we received was on the webinar was: Do I have to submit an application to participate in the DOS Demo?

The answer was: The only labs that need to apply by August 1st are those laboratories who have proprietary tests that meet the criteria for the DOS demo and are currently being submitted to Medicare for payment using an unlisted code. The purpose of the application is to assign a G code. There are 6 proposed buckets of G codes to be used for claims participating in the demo and for being submitted during the demo. If you are a hospital or lab submitting qualified tests that are totally based on a combination of the 36 identified codes, you don’t need to do anything except when January 1,2012 comes and the demo begins, just submit the claims using the 56 identifier.

We wanted to elaborate on this fact that sadly, it is looking like the companies who put so many resources and efforts into getting a mechanism in place that would provide relief to the “14 day rule” do not feel comfortable participating because of the many uncertainties over pricing, how their submitted information would be used, and the lack of specificity as to the metrics that will be utilized at the end of the demo.