CMS announced it is delaying enforcement of the Place of Service Policy the agency had announced on April, 2012. The HBMA and other healthcare organizations sought this delay and had also been aggressively pushing CMS to change its policy. The effective date for the “new” policy is April 1, 2013. Click here to review the entire Policy.
Unfortunately, the “new” Place of Service Policy is not substantially different from the policy announced in April, 2012. The key problem remains the identification of the physical location of the physician at the time he/she reviews a medical image. The only concession was granting a clarification HBMA requested with respect to “infrequent” locations in which the professional component of a diagnostic test is performed.
This new policy presents huge technical and practical problems for physicians, medical billing companies and practice management software providers. Despite these efforts, it appears that CMS has largely ignored the industry’s concerns.
Your ADVOCATE representative will contact your group if assistance is needed in meeting this new requirement. We will provide more information as it becomes available.
Kirk Reinitz, CPA