Pathology/Lab Coding Alert

Stick with specimen acquisition.

You know that the date of service (DOS) for clinical lab tests and the technical component of pathology specimens is the collection date - The Medicare Claims Processing Manual, Chapter 16, Section 40.8 stipulates as much.

With no current specific DOS guidance for the professional component of pathology specimens, the following logic has compelled 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 number SE17203 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Wait: CMS has issued similar guidance in the past and rescinded it, based on stakeholder input. Before making the change in how you bill, watch Medicare memos and Pathology/Lab Coding Alert for possible updates on the ruling.