CMS cancels place-, date-of-service guidance

The U.S. Centers for Medicare and Medicaid Services (CMS) has withdrawn a proposal it made in December that would have required physicians to report the specific date and place of service where the professional and technical components are provided, the agency said.

The change was to be implemented January 4 and would have wrought chaos for imaging providers, according to a coalition of industry organizations that lobbied against the proposal. The group won a six-month delay in the date-of-service portion of the original transmittal; it was working to seek a similar grace period for the place-of-service instruction as well when CMS announced it had rescinded the whole guidance.

The coalition opposing the new rule included the American College of Radiology (ACR), Association for Medical Imaging Management (AHRA), Healthcare Billing and Management Association (HBMA), Medical Group Management Association (MGMA), and Radiology Business Management Association (RBMA).

Because billing software cannot easily isolate Medicare-only claims, the instruction could have caused the existing place-of-service/date-of-service conventions to be applied to all payors, not just Medicare, the group told CMS. To avoid this, physician practice management system vendors would have to program new fields into their software, test them, and retrain their users, leading to a delayed submission of Medicare claims and compounded cash-flow problems -- not a pretty picture as radiology practices brace for impending cuts, the coalition wrote in a December 18 letter to CMS.

In a statement sent on February 5, CMS said it will release a revised change request in the future, pending further policy clarification on date-of-service and place-of-service reporting for interpreting diagnostic tests, and the revised change request will address the full spectrum of clinical scenarios.

"[CMS'] instructions were very controversial and guidance from Medicare carriers on how to implement the new coding varied widely," said Tom Greeson, a partner at Reed Smith of Falls Church, VA, who specializes in radiology-related regulatory matters. "Cleary, further thought on how to make billing for interpretation services more transparent was needed. CMS' announcement has been met with applause by radiology groups and their billing professionals."

By Kate Madden Yee
AuntMinnie.com staff writer
February 8, 2010

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