Revenue Cycle Insider

Compliance:

Avoid DOS Errors With the CMS 14-Day Rule

Question: The provider collected a patient’s buccal swab and saliva on August 10. The saliva specimen was not tested until 14 days later. My colleague warned me of a “14-day rule” related to laboratory services. Would that change the date of service (DOS) for billing purposes?

Ohio Subscriber

Answer: The Centers for Medicare & Medicaid Services’ (CMS’) Laboratory Date of Service Policy, which is more commonly known as the “14-day rule,” generally assigns the specimen collection date as the DOS for clinical laboratory testing. In certain situations covered by the rule, however, the DOS is based on the date the test is performed rather than when the specimen was obtained.

Taking a mouth swab for DNA analysis

Some of these exceptions can include advanced diagnostic laboratory tests (ADLTs), molecular pathology tests, cancer-related protein-based multianalyte assays with algorithmic analyses (MAAAs), and 81490 (Autoimmune (rheumatoid arthritis), analysis of 12 biomarkers using immunoassays, utilizing serum, prognostic algorithm reported as a disease activity score). 

For these tests, CMS regards the DOS as the date of the actual test, providing:

  • “The test was performed following … a discharge from the hospital outpatient department, 
  • “The specimen was collected from a hospital outpatient during an encounter,
  • “It was medically appropriate to have collected the sample from the hospital outpatient during the hospital outpatient encounter, 
  • “The results of the test do not guide treatment provided during the hospital outpatient encounter,” and
  • “The test was reasonable and medically necessary for the treatment of an illness.”

In your particular case, however, the DOS would still be August 10.

Lindsey Bush, BA, MA, CPC, Production Editor, AAPC

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