Billing Beat

Date of Service for Anatomical Pathology Services

October 30, 2013

The date of service (DOS) for the professional component of anatomical pathology services is the date the professional component was completed. This is the date the physician evaluated the specimen and created the report. This may be different from the DOS of the technical component. Medicare requires providers to bill services based on the date they were performed. If the professional and technical were not performed on the same date, then submitting a global charge is inappropriate. Generally this same rule applies to the technical component. CMS Internet-Only Manual (IOM) Publication 100-04, Chapter 16, Section 40.8 discusses the requirements and discusses an exception. The exceptions are for clinical laboratory tests and the technical component of pathology specimens. The general rule is the DOS is the date the specimen was collected. For example, this is the date the blood was drawn or the anatomical specimen was collected. There is a variation in that if a specimen is collected over a multiple day span, then the DOS must be the date the collection ended. In the case of a stored specimen, then if it was stored equal to or less than 30 days, the DOS is the date performed. The IOM lists several requirements for that rule. If the specimen was stored for more than 30 days, then the DOS is the date the specimen was obtained from storage.

MAC J5 for Iowa, Kansas, Missouri, and Nebraska and MAC J8 for Indiana and Michigan

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