Radiology Coding Alert

Question: Radiology Coding Alert, Vol. 11, No. 14, referred to CMS Transmittal 1823, but I heard CMS rescinded this. Where can I find the replacement transmittal?

Tennessee Subscriber

Answer: 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.

Although practices weren’t too surprised to see instructions to choose the POS based on where the clinician performs the service, the DOS instruction has caused a bit more confusion. The transmittal indicates that you should choose the actual interpretation date as the DOS for diagnostic image interpretation. Practices performing global services have been asking if that means they must split the professional and technical components if they perform the test one day and interpret it on another.

Several specialty societies asked CMS to delay the implementation date both to allow them to raise their concerns and to allow practices to prepare for the change, should it go through. Stay tuned to Radiology Coding Alert for future updates.