In the recently published proposed rule related to the CY 2018 Hospital Outpatient Prospective Payment System (OPPS), the Centers for Medicare & Medicaid Services (CMS) announced that it is considering changes to the regulation governing the date of service (DOS) for clinical laboratory and pathology specimens.  The DOS rules are important to laboratories and hospitals because they dictate which party must bill Medicare for certain laboratory testing performed on stored specimens collected during a hospital procedure but ordered after the patient has left the hospital.  If revisions are ultimately finalized, the proposal could have significant business implications for independent laboratories and hospitals.

Continue Reading CMS May Decide to Permit Labs to Bill for Certain Tests Provided to Outpatients

Written by: Karen Lovitch and Lauren Moldawer*

As part of the Outpatient Prospective Payment System (OPPS) Rule issued last week, the Centers for Medicare & Medicaid Services (CMS) finalized its proposal to conditionally package certain ancillary services assigned to APCs with a “geographic mean cost” of $100 or less.  This change, which will take effect on January 1, 2015, will apply to the technical component of most anatomic pathology services.  Because the hospital’s payment for the primary procedure will cover these services, the hospital may no longer bill for them separately.  But physicians can continue to seek reimbursement under the Medicare Physician Fee Schedule for the professional component of the service. Continue Reading CMS Finalizes OPPS Rule Packaging Pathology Services Ordered for Hospital Outpatients