Puzzling out the positive shift in the final 14-day rule

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Fetter

Building the new 14-day rule into Xifin software has been a priority for the company. “As part of our package, all of our customers have to have the most current regulations, so what we had to do was say, ‘Okay, if this particular test is on a patient who is an outpatient, we need to create system logic that identifies and facilitates resolution of the problem so the lab isn’t billing for an incorrect date of service.’” If, for example, there is an outpatient procedure performed and discharge at the end of one day, and the testing was performed after that, “that’s relevant and fairly standard in molecular testing. So from our perspective we have to make sure we correctly identify when there is going to be a requirement for date of service to be based on the report date as opposed to the sample collection date.”

It’s a little more challenging for independent labs, Fetter adds, to make sure they understand exactly when the discharge date was for each outpatient procedure and are able to bill for that effectively. “You don’t want to set yourself up in a scenario where you’re actually billing for procedures routinely and waiting to get a denial from the Medicare program. That can be a compliance issue. Systems need to be able to account for processes like this to keep their labs from getting into trouble.”

Fetter stresses two important messages for laboratories about the new 14-day rule. First, “Obviously keep close track of what tests are being considered under this rule, and there are different resources labs can utilize to figure out which tests are excluded. That’s the big one. Second, you have to have really good tools for making sure you understand, in the case of a Medicare outpatient, when the discharge date is, when the test was completed, and when the collection date is. You want heavy automation compliance around these processes because you don’t want clerical decision-making driving incorrect changes in the date of service.”
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Anne Paxton is a writer and attorney in Seattle.