Laboratory Question for the Week of August 20, 2018

Laboratory Compliance Question of the Week


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.

This and other details can be found at

Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.