Pathology/Lab Coding Alert

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

Florida 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: Many labs find the DOS rule confusing and potentially very difficult to implement. The transmittal indicates that you should choose the actual interpretation date as the DOS for diagnostic test interpretation.

Too many questions: Labs have a lot of questions that need answering before they can implement the policy. For instance, must you use a different DOS for the gross and microscopic exam or ancillary services such as special stains if the lab and pathologist complete the services on different dates? Does the policy mean that you can't bill a global charge because CMS requires labs to use the specimen collection date as the DOS for technical component charges?

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

For more information on the guidelines for DOS and POS changes that will impact your lab, stay tuned to future issues of Pathology/Lab Coding Alert.