CMS Clarifies Billing Policy for Lab Services

It seems the new date of service (DOS) for the technical component (TC) of pathology, mandated by the 2007 Medicare Physician Fee Schedule (MPFS) final rule and implemented May 23, 2008, has caused some confusion. Does the DOS requirement apply to pathology tests when the TC and professional component (PC) are performed by the same lab and billed globally? Enquiring minds want to know!

To clarify, the Centers for Medicare & Medicaid Services (CMS) recently updated Pub. 100-04, Medicare Claims Processing Manual, chapters 1 and 16.

CMS transmittal 1744, change request 6457, issued May 22, clarifies Medicare policy by adding the following text:

“When the TC and PC of pathology services are performed on different Date of Service (DOS), they shall be billed as separate line items if the services are performed by the same independent laboratory.” Global billing is not appropriate in this instance.

This guidance is effective Aug. 24.

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