Pathology/Lab Coding Alert

Reader Question:

Forget Professional Component DOS Instruction

Question: I heard that Medicare issued a memo that we must bill the pathologist's professional component of anatomic pathology services using the date the pathologist does the exam, while the date of service for the technical component remains the date of specimen collection. Is this true?

Codify Subscriber

Answer: Yes, it's true, but don't panic - CMS has already rescinded the memo. You must still report the technical component using the date of specimen collection (with exceptions), but you do not have a requirement for what date of service (DOS) to report for the professional component.

What happened: CMS issued MLN Matters number SE17023 on September 19, 2017 and rescinded the order on October 2, 2017. But concern about the memo lingers as people continue to hear rumors.

Tricky: Stakeholders are relieved because reporting two dates of service for the different components of a single service could cause the following problems:

  • Global billing is not possible, but you must instead bill twice, once using modifier TC (Technical component) and once using modifier 26 (Professional component)
  • Lab billing software may not accommodate different dates of service for the same procedure
  • Filing two claims may make it difficult to link a single service, and may look like duplicate billing.