DOS for professional component

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I participated in WPS' teleconference today regarding POS billing, and ended it with more confusion than when I started. The main focus of the event was to convey POS billing for interpretation services...that even if the dr interprets the test while at his office, the POS is where the beneficiary received the test. So...I understand that if, for instance, a capsule endoscopy was done at the outpatient hospital (POS 22), but read in our office (POS 11), we still bill out the professional component with POS 22. No problem there.
My confusion is the DOS for the interpretation. According to the WPS presenter, I should be billing out the DOS as the day he read the test.
What happens if it's an in-patient and the test is read after discharge? My DOS for POS 21 will fall outside the range of hospitalization dates. Won't that be a problem?
 

mitchellde

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I have always used the DOS as the date of the test. The new transmittal regarding POS did not address the DOS issue at all.
 
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I have always used the DOS as the date of the test. The new transmittal regarding POS did not address the DOS issue at all.
We have too. I didn't read that out of that transmittal either, but that was the topic of discussion during the Q&A portion of the teleconference. Many callers asked about the scenario I posted here, and in each instance she stated that the DOS should be the date the test was read. One caller even stated that her software program won't allow her to enter a date past the hospitalization dates, and the presenter still insisted that the DOS was the date it was read.
 

mitchellde

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until you get some kind of official news I would continue to use the date of the test, that is what I have always been told and it has always worked. I will do some digging and see what I find.
 
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Thanks Debra.
Any other thoughts out there? Something came across my email a few weeks ago about billing out the DOS as the date it was actually read, and I even thought at the time, "I wonder if this only applies to Radiology interpretation". That's why I signed up for the medicare teleconference that I attended yesterday.
 
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Thanks for the link! I knew I had seen something and couldn't find it yesterday.

Now, that being said. Does this only apply to radiology services? In the teleconference, the presenter was even referring to pacemaker phone checks.
If not, Is it "okay" to bill for a reading fee on an inpatient study with a DOS after the inpatient stay has ended? My POS will be 21, but my DOS will fall outside of the hospital stay.
 
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grth97

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This is what we are concerned with as well...I am going to ask the online help when they open at 11am. I will post what I find out.
 

Pam Brooks

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DOS means "date of service". With that, the service we're providing is the professional read/interpretation-not the actual test. We have always billed the interpretation as the date the doc read the test...even if the test POS was 21 and even if the patient has been discharged, without issues. Besides: here's the regulatory guidance.

10.6.3
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]- [/FONT][/FONT]Date of Service (DOS) Instructions for the Interpretation and Technical Component of Diagnostic Tests
(Rev. 1873, Issued: 12-11-09, Effective: 01-04-10, Implementation: 07-01-10)
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]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 30[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]th [/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]and the interpretation was read on May 2[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]nd[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman], 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 2[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]nd[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman].
[/FONT][/FONT]
 
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DOS means "date of service". With that, the service we're providing is the professional read/interpretation-not the actual test. We have always billed the interpretation as the date the doc read the test...even if the test POS was 21 and even if the patient has been discharged, without issues. Besides: here's the regulatory guidance.

10.6.3
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]- [/FONT][/FONT]Date of Service (DOS) Instructions for the Interpretation and Technical Component of Diagnostic Tests
(Rev. 1873, Issued: 12-11-09, Effective: 01-04-10, Implementation: 07-01-10)
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]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 30[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]th [/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]and the interpretation was read on May 2[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]nd[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman], 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 2[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]nd[/FONT][/FONT][FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman].
[/FONT][/FONT]
Pam,
Do you know if this applies to all professional services, or just radiology services?
 

Pam Brooks

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The transmittal doesn't differentiate. Transmittal 1873:
SUBJECT: Place of Service (POS) and Date of Service (DOS) Instructions for the Interpretation (Professional Component) and Technical Component of Diagnostic Tests
 
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The transmittal doesn't differentiate. Transmittal 1873:
SUBJECT: Place of Service (POS) and Date of Service (DOS) Instructions for the Interpretation (Professional Component) and Technical Component of Diagnostic Tests
Pam,
I was trying to find the post you and I commented on earlier about this. I am still trying to clarify this for our region(Cahaba). Transmittal 1873 was rescinded wasn't it?

Thanks,
 

Pam Brooks

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Transmittal 1823 is rescinded and replaced by Transmittal 1873. The implementation date for Business Requirement 6375.10 and section 10.6.3 only of the manual instruction has been changed to July 1, 2010. All other information remains the same.

I've attached the entire document.
 

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Update

I just spoke with a representative from WPS. She states that all professional (reading/interp) services are billed as follows:
The technical component is billed the day the service is performed, using the POS the day the service was performed. The professional component (26) is billed the day of the interpretation, using the same POS as the day the service was rendered. I specifically asked if this only applied to radiology services and was told it applied to all interpretation services. I also specifically asked about capsule endoscopies performed in our office, as we normally would bill global. I was informed if the capsule was not read the day it was performed, we could not bill global. We would need to bill the TC out the day the patient swallowed the capsule, then bill out the -26 the day our provider read it.
Now, she did tell me there are a few exceptions. One was archived pathology specimens - that DOS is the day it was retrieved from archive. Another was tests are are performed over a span of days.
We also discussed what would happen if the patient was an in-patient, was discharged, and the test wasn't read until after discharge. The same rules apply, but she also stated Medicare would question the medical necessity of doing an in-patient test that didn't need to be read while the patient was still in the hospital.
She also told me this is not a new directive.
I spoke with our capsule rep, and they plan to investigate to clarify as well.
 
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Transmittal 1823 is rescinded and replaced by Transmittal 1873. The implementation date for Business Requirement 6375.10 and section 10.6.3 only of the manual instruction has been changed to July 1, 2010. All other information remains the same.

I've attached the entire document.
Pam,
Yes I see that now. Thank you for the attachment. The DOS portion was not revised.
 

MCCONKEYT

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Radilogy Date of Service Issue

I know this is late in posting but I have been researching this issue for quite some time for the radiology groups we bill for. The date of service ruling was tacked on the POS ruling as an afterthought seems to me. Then they rescinded the POS transmittal 2613 and replaced it with 2679. See change request CR7631. We are going with the date of the interp. even though it is causing us problems because I can find nothing out there that specifically states go with the date of the test. The CMS website listed above is no help. It just gives guidance on where to put the date of service. Nothing was said in the 2679 or the CR7631 about date of service. They pretty much left it dangling. Try calling your MAC. I did and got nowhere though.

Contact with Novitas led to the following link.

https://www.novitas-solutions.com/faq/partb/pet/billing.html#6
What is the appropriate date of service to use when a test has been interpreted?

The interpretation must be billed with the date the physician actually provided the interpretation. The date of the professional component billed to Medicare Part B, and the date in both the supporting medical records and on the report must be in agreement. However, the date of the interpretation does not have to agree with the date of the technical component.[/I]

All it does is confuse the matter more. What does that middle sentence mean. If the physician documents he order the test on this date and it isn't read til a different date are they in agreement?

Our biggest problem is that the patient passes away before the interpretation date and then we are denied!!!!

I have some old documentation if anyone is interested. AND if anyone finds a definite answer on this one, please, please contact me.

By the way, they tried to do this for Path and it didn't go thru.
 

MnTwins29

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Very late - but found this and have add'l info

Hi - while I know this thread is over two years old, I have been researching this for our professional pathology billing as the pathologist services are now being billed in-house. I was asked the same question about the DOS and I have found that Pam's reference - Transmittal 1873 from 2010 - is still in effect and is what is being used for our MAC, NGS.

I also asked about the situation raised earlier about the patient expiring before the physician reads and interprets the test. For our carrier, I was advised that the claim will be denied and we should appeal using Transmittal 1873 as the basis for usiing that date and also may need to provide proof that the specimen/test was performed while the patient was still alive. i.e. pt had surgery and specimen removed 8/4/15, pt expired 8/5/15, MD read and interpreted 8/6/15 - would have to use 8/6/15, get the claim denied and then appeal.
 
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I am also researching this. All information I have been able to find indicates transmittal 1873 is completely rescinded.

CMS claims processing manual Ch 26.
https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c26.pdf
"Place of Service (POS) and Date of Service
(DOS) Instructions for the Interpretation
(Professional Component) and Technical
Component of Diagnostic Tests -Rescinded"

American College of Radiology also indicating this transmittal was rescinded and that now CMS does not offer direction one way or another:
http://www.acr.org/~/media/ACR/Documents/PDF/Economics/Medicare/DOS WPS CAC letter_final_112713am2.pdf
"Note: CMS did publish guidance in 2009 that mandated the service be billed with a date of service that was the actual calendar date that the interpretation was performed. This instruction was released in CR6375 and became effective January 4, 2010. However, this instruction was rescinded and negated by CMS on February 5, 2010. Since there is no policy, regulation, or other mandate from CMS stating a definitive stance on this issue, National Government Services has and will continue to follow its standard of leaving which date of service is billed for the professional component up to the provider."
 
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tsmith65

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Does anyone know the answer to this question?

so conflicting and confusing..... I have searched and searched and cannot find anything definitive on this. From this thread it appears CR6375 rev 1873 was rescinded before it was even fully implemented and there has been nothing further since February 2010?
 

ellzeycoding

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There is no national rule. They attempted to, but rescinded it.

Therefore, it's Contractor-specific. A few years ago McKesson published an article summarizing the contractor-specific rules. The article has since been removed. But here was the chart from it.

chart.jpg
 
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