So I couldnt find the documentation myself so I posted the question on the ortho list serve to Margie Vaught and here is what she posted. some of this is the same as the link above but there is more that shows the concensus to be DOS, not date of interpretation.
Here is the scoop it should really be the DOS:
Here is some info regarding INTERPRETATION DOS:
100-04 Claims Processing Manual Section 100 Chapter 13-Radiology Svcs Subject Radiology SERVICEs and Other Diagnostic Procedures - Section 100 - INTERPRETATION of Diagnostic Tests:
"15023. INTERPRETATION OF DIAGNOSTIC TESTS
EXAMPLE A: A physician sees a beneficiary in the ER on January 1 and orders a single view chest x-ray. The physician reviews the x-ray, treats, and discharges the beneficiary. You receive a claim from a radiologist for CPT code 71010-26 indicating an INTERPRETATION with written report with a DATE of SERVICE of January 3. Pay the radiologist's claim as the first bill received. You do not have to develop the claim to determine whether the INTERPRETATION was a quality control SERVICE.
EXAMPLE B: Same circumstances as Example A, except that the physician who sees the beneficiary in the ER also bills for CPT code 71010-26 with a DATE of SERVICE of January 1. Pay for the first claim received. If the first claim is from the treating physician in the ER, and there is no indication the claim should not be paid, e.g., no reason to think that a complete, written INTERPRETATION has not been performed, payment of the claim is appropriate. Deny a claim subsequently received from a radiologist for the same INTERPRETATION as a quality control SERVICE to the hospital rather than a SERVICE to the individual beneficiary.
EXAMPLE C: Same as Example B except that the claim from the radiologist uses modifier -77 and indicates that, while the ER physician's finding that the patient did not have pneumonia was correct, there was also a suspicious area of the lung suggesting a tumor that required further testing. In such situations, pay for both claims under the fee schedule. EXAMPLE D: You receive separate claims for CPT code 71010-26 from a radiologist and a physician who treated that patient in the ER, both with a DATE of SERVICE of January 1. Develop the claim to determine whether the findings of the radiologist's INTERPRETATION were conveyed to the treating physician (orally or in writing) in time to contribute to the diagnosis and treatment of the patient. If the radiologist's INTERPRETATION was furnished in time to serve this purPOSe, that claim should be paid, and the claim from the other physician should be denied as not reasonable and necessary."
Here is what one Medicare carrier has: Medicare Part B Bulletin HGS: Sept 04 Publish DATE August 2004 States Affected PA Subject Billing Professional/Technical Component?
"
If you report the DATE of SERVICE you rendered a professional component or INTERPRETATION of a technical SERVICE, that same DATE should be referenced on your report or documentation. Conversely, if you report the DATE of SERVICE a technical component was performed, the DATE of the technical component should be referenced on your professional report or documentation. For example, a RADIOLOGY SERVICE is rendered on January 6, 2004 but the report or professional component is not rendered until January 9, 2004. The claim submission DATE of SERVICE is January 9, 2004. The report or documentation should state, “1/9/04 INTERPRETATION of RADIOLOGY SERVICE rendered 1/6/04.”
If the DATE of SERVICE you are using on the 1500 claim form does not match the DATE or there is no cross-referenced DATE on the report, the SERVICE may be denied as the record does not match the claim."
Medicare Part B Bulletin Nat'l Heritage: Mar 04 Publish DATE March 2004 States Affected ME, MA, NH, VT Subject Coding, Testing, and Implementation Phases of Claims Jurisdiction - CMS Revision "
Paper claims submitted for purchased SERVICEs with both the INTERPRETATION and the purchased test on one claim will be returned as unprocessable unless the SERVICEs are submitted with the same DATE of SERVICE and same PLACE of SERVICE codes. When a claim is received that includes both SERVICEs, and the DATE of SERVICE and PLACE of SERVICE codes match, NHIC will assume the one address in Item 32 applies to both SERVICEs. ANSI X12N 837 electronic claims submitted for purchased SERVICEs with both the INTERPRETATION and purchased test on the same claim must be accepted. NHIC will assume the claim level SERVICE facility location information applies to both SERVICEs if line level information is not provided."
Anesthesia Answer Book Effective DATE 01/01/2004 Publish DATE January 2004 Subject DATE of SERVICE
"
The correct DATE of SERVICE for billing the professional component of diagnostic tests such as X-rays, EKGs, Holter monitors, etc., is the same DATE of SERVICE as the technical component. The professional component (-26 modifier) should be filed with the same DATE of SERVICE as the technical component. It is recognized that the DATE the test was performed (TC) may not be the actual DATE on which the INTERPRETATION was done. However, the SERVICE may not be billed until the INTERPRETATION is performed and documented. To ensure that the appropriate reimbursement is made, Medicare says that it is important that the same DATE of SERVICE be filed for the total procedure, no matter if the procedure is billed globally or as component parts." Here is what CMS states: "DATE OF SERVICE The “DATE of service” is the official DATE of a Medicare expense. It’s usually the day you perform a service or deliver a medical item. (Medicare refers to the official expense day as the DATE an “expense is incurred”) [MCM 2005]. For most of Part B, simply ignore the DATE a procedure was ordered or the DATE it’s paid. The “DATE of service” is the DATE the doctor performs the service or the day the supplies arrive in your office. In practical terms, this means patients can schedule an exam before they are covered by Medicare—as long as they are covered by the time they walk into your office [MCM 2005]. If a medical service has several components that take place on different days, it’s probably not a good idea to lump them together under one DATE. The day the patient gets each part of a service is the day its expense “happens” or is officially “incurred.” Surgery is the biggest exception to this rule [see Surgery: Global Billing section].
The correct DATE of service for billing the professional component of diagnostic tests such as X-rays, EKGs, Holter monitors, etc., is the same DATE of service as the technical component. The professional component (-26 modifier) should be filed with the same DATE of service as the technical component. It is recognized that the DATE the test was performed (TC) may not be the actual DATE on which the INTERPRETATION was done. However, the service may not be billed until the INTERPRETATION is performed and documented. To ensure that the appropriate reimbursement is made, Medicare says that it is important that the same DATE of service be filed for the total procedure, no matter if the procedure is billed globally or as component parts. Another exception for some carriers – (check with yours) – is lab/X-ray/pathology tests. Carriers will usually allow you to put the DATE collected as the day of service. For instance, if the lab does the draw at 5 pm for a chem panel, and it’s actually run the next day, some carriers will say it’s okay to use the DATE of collection as the DATE of service. However, others take a tough stand and say the DATE of service is the DATE that you do the INTERPRETATION. Example: A patient has surgery and dies overnight. INTERPRETATION of the specimen is done the next day; so “the next day” would be the DATE of service. ¨"
Margie Scalley Vaught, CPC, CPC-H, CCS-P, MCS-P, ACS-EM, ACS-OR
Healthcare Consultant
Coding Content Specialist for DecisionHealth
scalley123@aol.com
cell 360-880-8304
fax 413-674-7668
www.margievaught.com
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