Q&A: Impact of the 14-day rule on laboratory date of service policy

Q: How does CMS' 14-day rule interact with its new molecular pathology/advanced diagnostic laboratory test (ADLT) policy?

A: Think about the 14-day rule as being more applicable to inpatients. Because there's a discharge date, and then if the physician decides or orders these tests 14 days or more after discharge, that's when a new account can be registered and the outpatient service can be billed separately by the performing lab. It’s no longer tied to that inpatient admission. But the 14-day rule, when it comes to outpatient molecular pathology and ADLTs, is no longer applicable for outpatients. You completely separate that from the outpatient encounter and the performing lab must bill, because if you look at those criteria, there's pretty much no outpatient account that isn't going to meet those criteria. The performing lab must bill that directly and there's no 14-day rule for outpatient molecular pathology and ADLTs.

Editor's note: Valerie Rinkle, MPA, CHRI, regulatory specialist for HCPro, a Simplify Compliance brand, answered this question during the HCPro webinar, “New Lab Date of Service Billing Requirements: Strategies for Success,”

This answer was provided based on limited information. Be sure to review all documentation specific to your own individual scenario before determining appropriate code assignment.

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