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Late last year the Centers for Medicare and Medicaid Services (CMS) issued a transmittal with new place of service rules that would have had an adverse effect upon many pathology providers, particularly those who purchase technical component processing from hospital laboratories and bill globally for the purchased technical component services and their professional interpretations for non-hospital Medicare patients.

CMS had indicated that it would issue new guidance specific to laboratories and pathology providers, presumably prior to the April 1 effective date of the new transmittal that was published late last year.

It is our understanding that CMS has informed the College of American Pathologists that it will not be issuing such guidance prior to April 1 for laboratories and pathology providers, but will do so at a later date. In addition, it is our understanding that in the meantime, CMS will instruct Medicare contractors to continue to apply the existing place of service guidance (that is, the place of service rules that have been in effect for the last several years) to laboratories and pathology providers. At this time, we do not have written confirmation of this position. Once we have written confirmation, we will send an updated alert.

For more information, please contact:

Jane Pine Wood


McDonald Hopkins has a large and diverse healthcare practice, which is national in scope. The firm represents a wide variety of healthcare providers, facilities, vendors, technology companies and associations. Our diverse experience enables us to give our clients a unique perspective on the issues that may confront them in the rapidly evolving healthcare environment.