Practice Management Alert

Question: Our pathology lab performs outside consults on referred slides from other institutions. What date of service should we use as the date of service -- the date of surgery, the date we receive the slides, or the date we dictate the report?

Answer: Per Medicare rules, you must use the specimen collection date as the date of service (DOS) for any technical component (TC) pathology service (such as 88323-TC, Consultation and report on referred material requiring preparation of slides, technical component) with two exceptions:

1. If you're using an archived specimen (one that's been in storage more than 30 days), you should use the date the specimen is taken from storage as the DOS.

2. If you're using a stored specimen (one that's been in storage at least 14 days but not more than 30 days), you should use the date you perform the service. Follow this rule only if you meet these criteria:

• Physician ordered the test/service at least 14 days following patient hospital discharge
• Physician collected specimen while patient underwent hospital surgical procedure
• Collecting sample other than during hospital procedure would be medically inappropriate
• Results of test/service do not guide treatment during hospital stay
• Test/service was reasonable and medically necessary.

Medicare doesn't give instruction concerning DOS for professional-only pathology services (such as 88321, Consultation and report on referred slides prepared elsewhere, and 88325, Consultation, comprehensive, with review of records and specimens, with report on referred material, which don't have a TC on the fee schedule), but most pathology practices follow the same guidelines for consistency. Non- Medicare payers may have different guidelines, and you should follow your payers' instructions.

Most of your outside consult requests will probably involve archived specimens, so you'll probably report the DOS as the date the specimen is taken from storage, in most cases.