For the Week of July 27, 2015
Have the Centers for Medicare & Medicaid Services (CMS) issued any information yet related to its plans for packaging of lab and pathology tests under the hospital outpatient prospective payment system (OPPS) for next year?
Yes, in the 2016 proposed rules for the hospital OPPS, CMS states that it would exclude all molecular pathology tests from the packaging policy. Currently, the following are excluded: 81200–81383, 81400–81408, and 81479. In 2016, all molecular pathology tests would be separately paid under the Clinical Laboratory Fee Schedule.
It also proposes to expand the current policy under which “conditional packaging” occurs when lab tests are provided on the same date of service (DOS) as the primary service and are ordered for the same purpose and by the same practitioner as the one who ordered the primary service. In fact, it proposes to package lab tests that are “integral, ancillary, supportive, dependent, or adjunctive to” a primary service or services provided in the hospital outpatient setting, regardless of the DOS. The only exception to this would be when a lab test is ordered for a different purpose and by a different practitioner than the practitioner who ordered the other OPPS service.
To view and archive of the Laboratory Compliance Question of the Week, click here