G2 Compliance Corner

What date of service should be used for the interpretation of a diagnostic test (professional component or PC) when the PC is performed on a different day than the technical component?

The Centers for Medicare and Medicaid Services has not provided any guidance or a specific policy that addresses this, according to the Jurisdiction 6 Part B Medicare Administrative Contractor (MAC), National Government Services (NGS). In an item published on its Web site, NGS states the following: “There is no policy from the Centers for Medicare and Medicaid Services (CMS) that requires billing to be one way or the other. As a result, we will process claims for diagnostic testing procedures with a date of service that is reflective of the day in which either the professional component (i.e., interpretation) or the technical component of the diagnostic testing procedures was performed.”

Laboratories should check with the MAC in their own jurisdiction to see if the contractor has published a policy on this topic. If there is no policy, laboratories should pick the date of service that best fits their processes until CMS issues a policy that provides specific information. At the same time, laboratories should not interpret this to address global billing issues. Global billing is a separate issue and must be addressed separately.

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