# What place of service do we use?



## Partha (Aug 14, 2009)

An in-patient got an x-ray during the hospital stay.  The patient was in the hospital from 12/2/08 until 12/4/08.  The doctor did not read and interpret the report until 12/5/08.  How do we bill this? on dos 12/5/08? What place of service do we use?


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## kalinahsmom (Aug 14, 2009)

I would say the date the patient received the service is the date of service and place of service would be inpatient.


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## LLovett (Aug 14, 2009)

With any service provided your documentation must support what is billed.

In the case of a service made up of technical and professional components that do not have to be done at the same time or in the same place, you should bill for the piece you did in the way that is supported by your documentation.

If the x-ray is read and report dictated on 12/5 that is what you should use for your date of service. The place of service really doesn't matter for the professional fee as far as amount goes, they pay the same no matter where it was done, so I would use the place of service where he read and did the report. With my providers they use a different system to dictate for inpatient than outpatient so it is very clear where something was done.

Laura, CPC, CEMC


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## mbort (Aug 14, 2009)

I could swear I have read something in contrary to what laura stated.  I think that the report is supports to match the date of exam....I'm going to research this some more...I'll be back to either eat my words or post documentation to support


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## LLovett (Aug 14, 2009)

http://www.medicarenhic.com/providers/articles/hospitalxray-ekg_0507.pdf

Hope this helps,

Laura, CPC, CEMC


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## mbort (Aug 17, 2009)

So I couldnt find the documentation myself so I posted the question on the ortho list serve to Margie Vaught and here is what she posted.  some of this is the same as the link above but there is more that shows the concensus to be DOS, not date of interpretation.

Here is the scoop it should really be the DOS:

Here is some info regarding INTERPRETATION DOS: 
100-04 Claims Processing Manual Section 100 Chapter 13-Radiology Svcs Subject Radiology SERVICEs and Other Diagnostic Procedures - Section 100 - INTERPRETATION of Diagnostic Tests: 
"15023. INTERPRETATION OF DIAGNOSTIC TESTS 
EXAMPLE A: A physician sees a beneficiary in the ER on January 1 and orders a single view chest x-ray. The physician reviews the x-ray, treats, and discharges the beneficiary. You receive a claim from a radiologist for CPT code 71010-26 indicating an INTERPRETATION with written report with a DATE of SERVICE of January 3. Pay the radiologist's claim as the first bill received. You do not have to develop the claim to determine whether the INTERPRETATION was a quality control SERVICE. 

EXAMPLE B: Same circumstances as Example A, except that the physician who sees the beneficiary in the ER also bills for CPT code 71010-26 with a DATE of SERVICE of January 1. Pay for the first claim received. If the first claim is from the treating physician in the ER, and there is no indication the claim should not be paid, e.g., no reason to think that a complete, written INTERPRETATION has not been performed, payment of the claim is appropriate. Deny a claim subsequently received from a radiologist for the same INTERPRETATION as a quality control SERVICE to the hospital rather than a SERVICE to the individual beneficiary. 

EXAMPLE C: Same as Example B except that the claim from the radiologist uses modifier -77 and indicates that, while the ER physician's finding that the patient did not have pneumonia was correct, there was also a suspicious area of the lung suggesting a tumor that required further testing. In such situations, pay for both claims under the fee schedule. EXAMPLE D: You receive separate claims for CPT code 71010-26 from a radiologist and a physician who treated that patient in the ER, both with a DATE of SERVICE of January 1. Develop the claim to determine whether the findings of the radiologist's INTERPRETATION were conveyed to the treating physician (orally or in writing) in time to contribute to the diagnosis and treatment of the patient. If the radiologist's INTERPRETATION was furnished in time to serve this purPOSe, that claim should be paid, and the claim from the other physician should be denied as not reasonable and necessary." 

Here is what one Medicare carrier has: Medicare Part B Bulletin HGS: Sept 04 Publish DATE August 2004 States Affected PA Subject Billing Professional/Technical Component? 
"If you report the DATE of SERVICE you rendered a professional component or INTERPRETATION of a technical SERVICE, that same DATE should be referenced on your report or documentation. Conversely, if you report the DATE of SERVICE a technical component was performed, the DATE of the technical component should be referenced on your professional report or documentation. For example, a RADIOLOGY SERVICE is rendered on January 6, 2004 but the report or professional component is not rendered until January 9, 2004. The claim submission DATE of SERVICE is January 9, 2004. The report or documentation should state, “1/9/04 INTERPRETATION of RADIOLOGY SERVICE rendered 1/6/04.”
If the DATE of SERVICE you are using on the 1500 claim form does not match the DATE or there is no cross-referenced DATE on the report, the SERVICE may be denied as the record does not match the claim."  
Medicare Part B Bulletin Nat'l Heritage: Mar 04 Publish DATE March 2004 States Affected ME, MA, NH, VT Subject Coding, Testing, and Implementation Phases of Claims Jurisdiction - CMS Revision "Paper claims submitted for purchased SERVICEs with both the INTERPRETATION and the purchased test on one claim will be returned as unprocessable unless the SERVICEs are submitted with the same DATE of SERVICE and same PLACE of SERVICE codes. When a claim is received that includes both SERVICEs, and the DATE of SERVICE and PLACE of SERVICE codes match, NHIC will assume the one address in Item 32 applies to both SERVICEs. ANSI X12N 837 electronic claims submitted for purchased SERVICEs with both the INTERPRETATION and purchased test on the same claim must be accepted. NHIC will assume the claim level SERVICE facility location information applies to both SERVICEs if line level information is not provided." 

Anesthesia Answer Book Effective DATE 01/01/2004 Publish DATE January 2004 Subject DATE of SERVICE 
"The correct DATE of SERVICE for billing the professional component of diagnostic tests such as X-rays, EKGs, Holter monitors, etc., is the same DATE of SERVICE as the technical component. The professional component (-26 modifier) should be filed with the same DATE of SERVICE as the technical component. It is recognized that the DATE the test was performed (TC) may not be the actual DATE on which the INTERPRETATION was done. However, the SERVICE may not be billed until the INTERPRETATION is performed and documented. To ensure that the appropriate reimbursement is made, Medicare says that it is important that the same DATE of SERVICE be filed for the total procedure, no matter if the procedure is billed globally or as component parts." Here is what CMS states: "DATE OF SERVICE The “DATE of service” is the official DATE of a Medicare expense. It’s usually the day you perform a service or deliver a medical item. (Medicare refers to the official expense day as the DATE an “expense is incurred”) [MCM 2005]. For most of Part B, simply ignore the DATE a procedure was ordered or the DATE it’s paid. The “DATE of service” is the DATE the doctor performs the service or the day the supplies arrive in your office. In practical terms, this means patients can schedule an exam before they are covered by Medicare—as long as they are covered by the time they walk into your office [MCM 2005]. If a medical service has several components that take place on different days, it’s probably not a good idea to lump them together under one DATE. The day the patient gets each part of a service is the day its expense “happens” or is officially “incurred.” Surgery is the biggest exception to this rule [see Surgery: Global Billing section]. The correct DATE of service for billing the professional component of diagnostic tests such as X-rays, EKGs, Holter monitors, etc., is the same DATE of service as the technical component. The professional component (-26 modifier) should be filed with the same DATE of service as the technical component. It is recognized that the DATE the test was performed (TC) may not be the actual DATE on which the INTERPRETATION was done. However, the service may not be billed until the INTERPRETATION is performed and documented. To ensure that the appropriate reimbursement is made, Medicare says that it is important that the same DATE of service be filed for the total procedure, no matter if the procedure is billed globally or as component parts. Another exception for some carriers – (check with yours) – is lab/X-ray/pathology tests. Carriers will usually allow you to put the DATE collected as the day of service. For instance, if the lab does the draw at 5 pm for a chem panel, and it’s actually run the next day, some carriers will say it’s okay to use the DATE of collection as the DATE of service. However, others take a tough stand and say the DATE of service is the DATE that you do the INTERPRETATION. Example: A patient has surgery and dies overnight. INTERPRETATION of the specimen is done the next day; so “the next day” would be the DATE of service. ¨" 

Margie Scalley Vaught, CPC, CPC-H, CCS-P, MCS-P, ACS-EM, ACS-OR
Healthcare Consultant
Coding Content Specialist for DecisionHealth
scalley123@aol.com
cell 360-880-8304 
fax 413-674-7668
www.margievaught.com
for workshops and audio http://www.margievaught.com/calendar/index.cfm
Advanced Ortho Symposium Sept 14-16th 2009 - Come learn about everything Ortho related from front office, appeals, office procedures and surgical procedures shoulders - toes and spine http://www.decisionhealth.com/ortho2009/home.htm approved for 19 CEUs from AAPC


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## LLovett (Aug 17, 2009)

While I understand readings don't always happen the date the film was taken, and I think that the radiologist reading should use the date that the film was done if the film was done with the intention of them reading it.

When your provider is not a radiologist and is most likely not the only one to read the film, I think it is pretty clear you should use the date of service that it was done on.

One of the biggest problems I have with this information is the statement that the technical component can't be billed unless the interpretation is done. The hospital I work in has arrangements with many local physicians that they do the x-ray or whatever and no one reads it in house, it is sent to that physician. Based on this logic they would not be able to bill for doing those until the interpretation was done, the hospital has no way of knowing if the doctor did it or not.

Purchased tests are a whole different ball game all together as well.

Not to be argumentative but in a situation where you are not the first and only one reading a test, billing it in a way just to get paid as opposed to a way that is supported by your documentation, seems to be asking for trouble in my opinion.

Laura, CPC, CEMC


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## slrollings (Aug 17, 2009)

I couldn't say about x-rays, but this scenario comes up quite often in a pathology practice I used to work for. The correct date of service is the date the test was taken, regardless of the date it was read. There are rare circumstances when an old slide will be pulled for further info, and if it was more than 30 days old, it was to be billed under the date it was requested. I don't have the reference in front of me, but have verified it in the past. I would think radiology would go along the same standards.
Just my humble opinion


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## slrollings (Aug 17, 2009)

Oh, and the place of service code would have to match where the physician was sitting when he did the interp. The technical could be done at one hospital, and the physician could be at another hospital or an office two days later doing the interp and report.


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## RebeccaWoodward* (Aug 17, 2009)

*What date should we use when the physicians are interpreting tests?*

Answer:
Tests with multiple components, such as professional and technical, should be submitted with the date of service the individual component was performed on. For example if an x-ray is taken on a Monday and is not read until Tuesday, the dates of service are different. Submit the x-ray code with HCPCS modifier TC on the date the x-ray was taken, and the x-ray code with CPT modifier 26 on the date the x-ray was read.

If you are performing services which do not have professional and technical components, such as labs, submit the service with the date on which the entire service was completed. There are exceptions to this guideline for laboratory tests performed on archived specimens.

Resource: 

CMS Medicare Benefit Policy Manual (Pub. 100-02), Chapter 15, Section 20 (PDF, 1.21 MB) 
Guidance regarding date of service for archived speciments: 
CMS MLN Matters article MM6018 (PDF, 74 KB) 
CMS Medicare Claims Processing Manual (Pub. 100-04), Chapter 16, section 40.8 (PDF, 445 KB)


http://www.palmettogba.com/Palmetto...nostic Tests~42401E6CFC1899F98525760A006F6ABE


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## Partha (Aug 19, 2009)

Thank you all for chipping in with your inputs!!!


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## MCMAHONJ (Jan 3, 2014)

*Radiology do you post the professional fee on the DOS or the interpretation date.*

Can anyone help with this.  if you post a technical fee for 12/3 and a pro fee for 12/5 won't you be denied for the professional component.  it is my understanding that the DOS should match the pro read.  In a teaching facility the test is already completed by the resident and all the attending does is sign off on it after the fact.


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