In response to the American College of Radiology (ACR) and Radiology Business Management Association (RBMA), the Medicare Administrative Contractor (MAC), Novitas Solutions Inc., has revised its date of service (DOS) policy to now enable radiologists in more than 14 states and cities to bill for Medicare services using either the date of the technical exam or the date of professional interpretation as the DOS.
The billing FAQs from Novitas now reads as follows (found here):
What date of service should I report when completing a diagnostic interpretation on a different date from the actual test?
We recognize that providers do not always perform the professional component on the same date as the technical component. Many providers prefer to submit a claim with a date of service that reflects the day the professional component was performed, while others prefer to use the date of the technical component as the date of service for their professional component.
There is no policy from CMS that requires billing to be one way or the other. Since there is no specific policy, regulation, or other mandate from CMS on this issue, we will leave which date of service is billed for the professional component up to the provider.
Novitas is responsible for local Medicare coverage policies and claims processing in Jurisdiction L and Jurisdiction H. Jurisdiction L covers Pennsylvania, New Jersey, Maryland, Delaware and the Washington, D.C., metro area as well as Arlington and Fairfax counties in Virginia, the city of Alexandria, VA, the District of Columbia, and Montgomery and Prince George’s counties in Maryland. Jurisdiction H spans Colorado, Oklahoma, New Mexico, Texas, Arkansas, Louisiana, Mississippi, the federal Indian Health Service and Veterans Affairs health facilities.
The ACR and RBMA’s joint letter to Novitas used language that mirrored another MAC’s policy, National Government Service, on the use of date of service.
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Lauren Sloan, MHA, RD, LD
Director of Regulatory Affairs