I don't have anything off hand to show this in writing but you are correct. Transcription date means absolutely nothing other than the service took place some time before it was transcribed. It can not be used as the date of service. This provider needs to amend the note and add the correct date of service in order to be compliant.
We have recently had many meetings regarding this in my facility (several providers here are using the same argument) our attorney has told them they have to document the date of service and told me not to bill any claims that don't have the proper supporting documentation.
This is really a common sense thing as well. I have a doctor that is always on the bad list because his dictation is behind. I recently saw him do a discharge 6 months after the actual date of service. Is it ok to use the transcrpition date of 2/15/10 for the date of service when in fact the service was actually 8/20/09? I don't think so.
Good luck, and if I find my supporting info I will post it. I was thinking AHIMA had a nice document but their site is horrible to search and I don't have time right now.
Laura, CPC, CPMC, CEMC
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