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Correct Reporting of Date of Service on Professional Medicare Claims

Correct Reporting of Date of Service on Professional Medicare Claims September 20, 2017

Yesterday, MLN Matters issued a new article outlining billing guidelines for reporting the date of service on professional claims.  The guidance addresses the following types of professional services:

  • Radiology
  • Surgical and Anatomical Pathology
  • Care Plan Oversight
  • Home Health Certification and Recertification
  • Physician End-Stage Renal Disease Services
  • Transitional Care Management
  • Clinical Lab Services
  • Home Prothrombin Time (PT/INR) Monitoring
  • Diagnostic Psychological and Neuropsychological Tests
  • Surgical Services

While the article indicates it does not present any new or revised Medicare policies, some of the guidance contained within the article directly conflicts with prior policy and MAC guidance.  As an example, historically, clinical laboratory and pathology providers were instructed to report the date of service as the date the specimen was collected.  The MLN Matters article published yesterday indicates providers must report the professional date of service as the date when the professional interpretation was rendered.  If the collection and interpretation occur on different dates, the services must be billed on different dates using the TC and 26 modifiers.  The new article also impacts radiology providers, as many MACs as well as the American College of Radiology (ACR) have historically taken the position that the date of service should be reflected as the date the images were obtained.  The new guidance indicates the professional date of service should be reported as the date when the professional interpretation was rendered.

The MLN article is located at:

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE17023.pdf

We recommend providers review the article against their specific MAC guidance and revise their billing policies and procedures accordingly.

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