Medicare Compliance & Reimbursement

Plus: IMPACT Act elements shouldn't impact you in 2018.

The date of service (DOS) for clinical lab tests and the technical component of pathology specimens is the collection date, according to The Medicare Claims Processing Manual, Chapter 16, Section 40.8.

However, with no current specific DOS guidance for the professional component of pathology specimens, most labs use the same (collection) date for technical and professional billing:

• A single DOS allows global billing when a single entity performs both services, as opposed to billing twice, once using modifier TC (Technical component) and once using modifier 26 (Profes­sional component).
• Lab billing software may not accommodate different dates of service for the same procedure.
• Filing two claims may make it difficult to link a single service, and may look like duplicate billing.

Now: CMS has issued guidance in MLN Matters SE 17203 stating that you should continue to bill the TC on the date of specimen collection, but that you must use the date the pathologist performs the professional exam as the DOS for that component.

Wait: CMS has issued similar guidance in the past and rescinded it, based on stakeholder input. So before you make the change in how you bill, check with your MAC for possible updates on the ruling.

In other news ...

You'll have one less thing to worry about this coming year, since Medicare officials have decided to hold off on proceeding with some new IMPACT Act data collecting.

Data elements identified for fiscal year 2018 proposed rules - cognitive function and mental status, special services, treatments and interventions, and impairments - "were not finalized," CMS said in a Sept. 28 Special Open Door Forum on the IMPACT Act.

CMS made the call "to be responsive to stakeholders' comments that the addition of standardized data elements 'are too much, too soon,'" CMS said in the forum. The delay should also "enable greater 'recovery' for providers between major releases."

The delay will also allow for additional reliability and validity testing, including testing on time points used in data collection. And it will give more time for stakeholders and Technical Expert Panels to build additional consensus on elements, CMS added.

Resource: To see the forum slides, visit www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/Downloads/Sept-2017-CMS-SODF-IMPACT-Act-92917_v2.pdf.