# Billing for Path POS 24 vs POS 11



## rlmiller (Aug 26, 2013)

We are a GI group that do procedures in our ASC.  Any specimens collected are taken to our Pathology Lab and processed and read by the Pathologist.  Since we own the equipement we bill for the TC and PC as a global charge.  We were using the POS (place of service) code 11, however we are getting denials stating the POS should be 24 ASC.  Is anyone else having this issue and how are you submitting claims for payment on both TC and PC as a global charge?

Please help me understand the confusing world of Medicare.
Thanks, Robin


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## mitchellde (Aug 26, 2013)

This was clarified in an transmittal with an implementation date of April1, 2013.  The POS is the place where the patient was at the time, not where the interpretation takes place.
This was:  transmittal 2613, dated december 14, 2012; implementation date april 1, 2013
.....
4. When there is no face-to-face service (e.g., the physician provides interpretation of a diagnostic test, only), the POS is that in which the beneficiary received the technical component (TC) of the service.


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## rlmiller (Aug 26, 2013)

Thanks Debra, I have read all the updates, however still have another question because this is were I am still in the fog.

for example I would bill 88305 with POS 24 with the Pathologist being the Rendering physician.  

Question - can we bill the global charge 88305 or can we only bill for the TC?


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## darlenasmith (Sep 12, 2013)

*GI Path*



rlmiller said:


> Thanks Debra, I have read all the updates, however still have another question because this is were I am still in the fog.
> 
> for example I would bill 88305 with POS 24 with the Pathologist being the Rendering physician.
> 
> Question - can we bill the global charge 88305 or can we only bill for the TC?



We are having the same problem.  Unfortunately, my Medicare carrier indicates that we can only bill for the Professional.  I am perplexed regarding the transmittal as it now indicates that it was rescinded and further information would be released about path clarification, but I am unable to locate that information.  

Any help would be greatly appreciated.  

Thanks,
Darlena Smith
Gastrointestinal Specialists, A.M.C.


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## darlenasmith (Sep 12, 2013)

*Path Issue*

I had an extended conversation with our Medicare carrier (Novitas) this afternoon.  I have been informed that we can still bill for Professional and Technical services performed by our pathology lab.  The problem arises when the patient presents to the hospital on the same date as our path/endoscopy charges.  It is assumed that the charges are related to the hospital services (inpatient or outpatient) and they recoup the technical component.  Apparently this problem is set to be resolved on 1/1/14 with MM8399, but until then charges must be appealed if they are denied for this reason.

Darlena Smith
Gastrointestinal Specialists A.M.C.


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## rlmiller (Sep 19, 2013)

Thanks for the response, we have also found out by our MAC (CGS) that we will need to appeal those Pathology claims that have denied or they are taking funds back.  We have sent all our appeals and are waiting to see what happens.  I really hope that the problem does get fixed in January.


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