Does the hospital still have the option to bill Medicare for the test if all of the conditions for the new laboratory DOS exception are met?
Revising the laboratory DOS policy for ADLTs and molecular pathology tests that are excluded from OPPS packaging policy effectively disconnects the laboratory test away from the hospital outpatient encounter so the “under arrangements” provisions do not apply. Given that the “under arrangements” rules would not apply to ADLTs and molecular pathology testing performed following the patient’s discharge from the hospital outpatient department, the laboratory must bill for the test. The hospital would no longer bill for these tests unless the hospital laboratory actually performed the test. That is, if the hospital laboratory performed the ADLT or molecular pathology test, then the hospital laboratory could bill Medicare for the test.
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