Date-of-Service Changes Affect AP Billing in J5

Recent changes to the date-of-service policy implemented by the Medicare contractor for Jurisdiction 5 (Iowa, Kansas, Missouri, and Nebraska) is having an impact on how anatomic pathology (AP) services are billed. According to the College of American Pathologists (CAP), Wisconsin Physician Services (WPS) has instructed providers billing Medicare part B that the billing date for professional component services should be the date that the pathologist actually provides the interpretation. When the technical and professional components are performed on different days, each component should reflect the actual date performed. WPS says this shift in policy is based on their interpretation of Medicare guidelines. Currently, most labs that perform both the technical component and professional component (PC) for AP specimens submit a global charge to their Centers for Medicare and Medicaid Services (CMS) contractor with the same date of service for both components. The Kansas Medical Society disagrees with WPS’s interpretation and has asked the CMS for clarification of the date-of-service rule for PC billing of diagnostic tests. But according to CAP, a senior staff person at CMS stated the agency “does not currently have a date-of-service policy and that it is up to the local MACs to establish policy for their respective jurisdictions.” Takeaway: Until CMS offers further clarification on date-of-billing issues, labs should check with their Medicare contractors regarding billing rules.