Match the Date of Service with the Date of Test Interpretation
Q: What date of service (DOS) should we use to report physician review and interpretation of Holter monitors (CPT® 93227 External electrocardiographic recording up to 48 hours by continuous rhythm recording and storage; review and interpretation by a physician or other qualified health care professional)? I’ve heard that we should use the date the test is initiated (e.g., when the monitor is placed), but also to use the date the physician reviews the information and signs off on his or her report.
A: Depending on your payer, the guidelines for assigning a DOS for 48-hour electroencephalogram (EEG) recording may have changed over time. In 2009, for example, the Centers for Medicare & Medicaid Services (CMS) issued Transmittal 1873 (Pub. 100-04 Medicare Claims Processing Manual, chapter 26, section 10.6.3, Date of Service (DOS) Instructions for the Interpretation and Technical Component of Diagnostic Tests), specifying that effective Jan. 4, 2010:
“The appropriate DOS for the professional component is the actual calendar date that the interpretation was performed. For example, if the test or technical component was performed on April 30th and the interpretation was read on May 2nd, the actual calendar date or DOS for the performance of the test is April 30th and the actual calendar date or DOS for the interpretation or read of the test is May 2nd.”
The Association for Quality Imaging (AQI), among other groups, objected to this policy, saying that it created a situation where you’d have to report the technical and professional components of a global service on different days, which could negatively affect patient care and complicate automated billing (see: http://associationdatabase.com/aws/AQI/asset_manager/get_file/13820). CMS subsequently removed section 10.6.3 from the Medicare Claims Processing Manual and has not yet directly replaced it with new instruction.
Effective April 1, 2011, CMS did, however, issue an attachment to its policy regarding 48-hour EEG (http://downloads.cms.gov/medicare-coverage-database/lcd_attachments/29584_13/L29584_CV016_CBG_040111.pdf), which stipulates:
“CPT codes for Holter monitoring services (CPT codes 93224-93227) are intended for up to 48 hours of continuous recording. For 48 hour monitoring codes (CPT 93224-93227):
- The documentation in the progress notes must reflect medical necessity for the service.
- These services may be reported globally with CPT code 93224. Use the date of physician review as the date of service (DOS).
- When submitting claims for the recording only (CPT code 93225) or for the analysis with report only (CPT code 93226) use the date the service was performed as the DOS.
- When submitting claims for physician review and interpretation (CPT code 93227) use the date the service was performed as the DOS.”
Per this instruction, whether you are reporting the “global” service (including recording and storage, scanning analysis with report, and physician review and interpretation, 93224 External electrocardiographic recording up to 48 hours by continuous rhythm recording and storage; includes recording, scanning analysis with report, review and interpretation by a physician or other qualified health care professional) or the physician component only (93227), the proper DOS will be the day the physician performs the review and interpretation (rather than the day the monitor was placed).
Most other payers conform to similar guidelines (which are also generally accepted by physician organizations and specialty societies), but you may wish to survey your non-Medicare payers to be sure you are reporting the correct DOS.