Monday, December 11, 2017

Very Brief Blog: Trade Journals on 2017 Changes in 14 Day Rule

Two trade journals have discussed the CMS 14 Day Rule scheduled to become effective on 1/1/2018.

There was a story in the recently created web news agency AXIOS, here.  It actually appeared in mid July 2017.   Note this Axios article links to a 16p cloud deck used in May to successfully explain the problem to CMS.

The news website DARK DAILY follow up with an extension of the storyline, on December 11, here.

image as seen in DARK DAILY article (see link in text)
I believe there is at least one major error in the TEXT of the rulemaking, which I discussed in a prior blog.   The new regulation and the basic concept of the rulemaking is to have Medicare "molecular pathology tests" - which they have been defining in practice for several years as human DNA RNA tests - be billable by the "performing lab," whether that be the hospital or an outside lab.   However, the body of the rulemaking discussion says that this change in billing excludes "genomic sequencing procedures" which makes no sense, and excludes PLA codes, which of course may be genomic sequencing procedures, tests of human DNA, and so on.   I  try to tell the story in a 4 slide online deck PDF, here, and the summary or finale slide is this:


For nerds, I discuss the communications methods used in the CMS deck obtained via AXIOS, here.