Radiology Coding Alert

Are you ready to implement the new rule for coding interpretation services?

For CMS rules, keeping up with effective dates is almost as tough as keeping up with the rules themselves.

Consider Medicare Transmittal 2407, which focuses on place of service (POS) coding rules, discussed in "CMS Update: POS 11 May Not Apply for Office Interpretations -- Here's Why" in Radiology Coding Alert, vol. 14, no. 4. At the time of the article's publication, the transmittal was set to be effective April 1, 2012, with an implementation date of April 2.

New effective date: CMS announced that the new effective and implementation dates have been set as Oct. 1, 2012. To review the rules and the announcement, you'll need to check Transmittal 2435, which replaced Transmittal 2407.

The new Transmittal states: "Transmittal 2407, dated February 3, 2012, is being rescinded and replaced by Transmittal 2435 to change the effective date from April 1, 2012, to October 1, 2012, and to change the implementation date from April 2, 2012, to October 1, 2012. This delay will allow CMS to address questions received and to make any necessary changes. All other information remains the same."

Area to watch: For radiology coders, one of the major issues the guidance addresses is choosing the POS code for a diagnostic test when the interpreting physician does not see the patient face-to-face. According to Transmittal 2407, and now Transmittal 2435, the general rule will be that you should choose the POS code based on where the patient had the face-to-face service. So under the new rule, if you're reporting a CT scan performed on an outpatient at the hospital, but your radiologist interprets the scan at his office, you would choose the POS code for outpatient hospital (POS 22).

Until the new rule becomes effective, continue to follow your payer's current guidance on choosing the POS code.

"Despite the implementation delay, you should review your POS coding policies" in light of the transmittal instructions to ensure that you're ready when CMS announces the final effective date, says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. and publisher of the Pathology Service Coding Handbook, in The Villages, Fla.

Resources: You may review Transmittal 2435 and its accompanying MLN Matters article at the following addresses:

www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads//R2435CP.pdf

www.cms.hhs.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM7631.pdf