When does the new laboratory DOS policy take effect?


Initially, the Centers for Medicare & Medicaid Services (CMS) set an implementation date of July 2, 2018 for the new laboratory date of service (DOS) exception policy. However, on July 3, CMS issued a notice saying that many entities require additional time to develop the systems’ changes necessary to enable the performing laboratory to bill for tests subject to the new policy. So, the agency said it will “exercise enforcement discretion” until January 1, 2019. Between now and then, CMS will not enforce the requirement that  the performing lab must bill for advanced  diagnostic laboratory tests (ADLTs) and  molecular pathology tests excluded from  the hospital OPPS packaging policy that  are subject to the new lab DOS except  until Jan. 2, 2019.

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