Answer: First, you should realize that the CMS date-of-service (DOS) rule applies to clinical lab tests and the facility technical component of anatomic pathology services/procedures. The policy does not apply to the professional component of anatomic pathology.
That said, the DOS policy for applicable services is as follows:
1. General rule— DOS is the date the specimen is obtained from the patient, with the following exceptions:
2. If the specimen has been stored more than 30 days, the DOS is the date the specimen is obtained from storage.
The following two rules apply only to procedures on specimens obtained from hospital inpatients or outpatients and stored 30 days or fewer (for non-hospital patients, just abide by rules 1 and 2):
3. If the physician orders a test on a stored specimen on the 1st through 13th day after a hospital patient’s discharge, use the date the specimen is obtained.
4. If the physician orders a test on a stored specimen on the 14th through 30th day after a hospital patient’s discharge, use the date that you perform the procedure.
Caveat: Rules 3 and 4 apply when it is medically appropriate to collect the specimen during the hospital procedure (such as a biopsy), and the test results didn’t guide treatment during the hospital stay.