January 02, 2020
The enforcement discretion period that had been in place for the last 18 months regarding the laboratory Date of Service (DOS) exception policy ends on January 2, 2020.
CMS had most recently adopted changes to the laboratory Date of Service (DOS) exception policy as part of the CY 2018 Hospital Outpatient Prospective Payment System (OPPS) rulemaking cycle. In response to stakeholder feedback that some providers may have challenges meeting the July 2, 2018 implementation as outlined in Change Request 10419, CMS had announced a 6-month enforcement discretion period with respect to the laboratory DOS exception. CMS had extended that 6-month enforcement discretion period two additional times.