OPPS date of service policy update impacts clinical laboratory reporting

March 27th, 2018

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews a CMS update to outpatient laboratory date-of-service policy under the OPPS, focusing on how molecular pathology tests and advanced diagnostic laboratory tests are treated for billing purposes. It also places the update in the context of Medicare hospital billing rules, specimen handling, under-arrangement relationships, and the operational changes hospitals and reference laboratories may need to consider. The piece is relevant to hospital revenue cycle staff, laboratory billing teams, compliance professionals, and others working with Medicare outpatient lab reporting.

Why This Topic Matters

The policy affects how hospitals and performing laboratories determine who bills Medicare and when, which can influence claim setup, internal workflows, and contract arrangements. Understanding the update helps organizations align outpatient laboratory reporting with CMS requirements while distinguishing it from existing inpatient and other outpatient laboratory rules.

Article Sections

  1. CMS outpatient laboratory date-of-service policy update

    Introduces the CMS change to outpatient laboratory date-of-service policy under OPPS and explains the general policy area affected.

  2. Background on packaging and separate payment for laboratory tests

    Describes the broader outpatient payment context for laboratory services and the policy setting in which the update applies.

  3. Hospital prohibition of unbundling and under-arrangement billing

    Summarizes Medicare hospital billing concepts related to specimen handling, outside laboratories, and billing relationships.

  4. Current date-of-service rules and exceptions

    Outlines existing outpatient laboratory date-of-service policy themes and the types of exceptions discussed in the article.

  5. New outpatient exception for molecular pathology and ADLT tests

    Explains the scope of the new outpatient exception and the general conditions CMS identifies for its use.

  6. Operational and contracting implications

    Covers the administrative and workflow considerations for hospitals and performing laboratories, including contract and claims process impacts.

  7. Effective date and implementation considerations

    Notes the policy timing and the need for organizations to review billing operations and related processes.

What You Will Learn

  • How CMS updated outpatient laboratory date-of-service policy under OPPS
  • How the policy interacts with hospital billing arrangements and specimen processing
  • What types of laboratory services are discussed in the article
  • Why hospitals and reference laboratories may need workflow changes
  • What broader Medicare policy framework surrounds the update

Who Should Read This

  • Hospital outpatient billing teams
  • Laboratory billing and compliance staff
  • Revenue integrity professionals
  • Reference laboratories
  • Medicare reimbursement specialists

Codes Discussed

  • CFR: 42 CFR § 411.15(m)(1)
  • CFR: 42 CFR 414.510(b)(1)
  • CFR: 42 CFR 414.510(b)(5)
  • CFR: 42 CFR 410.2
  • CFR: 42 CFR 409.3

Code Ranges Discussed

  • CPT: CPT/HCPCS

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