Cardiology Coding Alert

Question: Did CMS's date of service rules go into effect on Jan. 4 as planned?

Tennessee Subscriber

Answer: No. CMS changed the implementation date from Jan. 4 to July 1.

Where to look: CMS replaced Transmittal 1823 with Transmittal 1873 (www.cms.hhs.gov/transmittals/downloads/R1873CP.pdf). In short, Transmittal 1823 provided instructions on proper place of service (POS) and date of service (DOS) reporting. The only difference between the two transmittals is an implementation date change for the DOS instructions, changing the Jan. 4 date to July 1. The POS requirements are effective Jan. 4 in both transmittals.

DOS rule: Although practices weren't too surprised to see instructions to choose the POS based on where the clinician performs the service, the DOS instruction has caused a bit more confusion. The transmittal indicates that you should choose the actual interpretation date as the DOS for diagnostic test interpretation. Practices performing global services have been asking if that means they must split the professional and technical components when they perform the test one day and interpret it on another.

Several specialty societies asked CMS to delay the implementation date both to allow societies and practitioners to raise their concerns and to allow practices to prepare for the change, should it go through.

Resource: See "Satisfy OIG's POS Standards Using New CMS Advice" and "Prep for DOS Trouble If Test on Day 1, Reading on Day 2" in Cardiology Coding Alert, Vol. 12, No. 13, for more information on the guidelines, and stay tuned to future issues for updates.