Advanced Revenue Cycle Analytics: An Overview

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CMS recently released a document reminding physicians, non-physician practitioners, and others submitting claims of the guidelines for billing for date of service. The fact that they released this reminder indicates that many people are not following the guidelines correctly. Use this summary of the guidelines to refresh your practices and make sure you are following the correct procedures when billing for date of service.

Radiology Services

  • Technical Component (TC) is billed on the date the patient had the test performed.
  • Professional Component (PC) is billed on the date the review/interpretation is completed.
  • For billing a global service: the provider can either a) submit the PC with a date of service for the date when the review/interpretation was completed, or b) submit the date of service as the date the TC was performed.

Surgical & Anatomical Pathology

  • TC is billed on the date the specimen was collected.
  • PC is billed on the date that review/interpretation was completed.
  • For billing a global service: the provider can either a) submit the PC with a date of service for the date when the review/interpretation was completed, or b) submit the date of service as the date the TC was performed.
  • When collection spans two calendar days, bill for the date the collection ended.

There are further instructions for dealing with stored specimen. They are as follows:

Specimen Stored Less Than or Equal to 30 Days

If specimen were stored less than or equal to 30 days, the date of service that should be billed is the date the test or service was performed, only if:

  • The test or service is ordered by the physician at least 14 days following the date of the patient’s discharge from the hospital
  • The specimen was collected while the patient was undergoing a hospital surgical procedure
  • It would have been medically inappropriate to collect the sample other than during the procedure for which the patient was admitted
  • The results of the test or service do not guide treatment provided during the hospital stay
  • The test or service was reasonable and medically necessary for treatment of an illness

Specimen Stored Over 30 Days

If a specimen was stored for more than 30 days before testing, that specimen is considered to have been archived. In this case, the date of service should be billed as the date that the specimen was removed from storage.

Care Plan Oversight

Care Plan Oversight, or CPO, is physician supervision of a patient under either the home health or hospice benefit where the patient requires complex or multi-disciplinary care requiring ongoing physician involvement. In order to bill for CPO services, physicians must report 30 minutes or more per month of physician supervision.

  • The date of service billed for CPO services can either be the last date of the month in which CPO services were provided, or the date in which 30 minutes or more of CPO services were provided.
  • The claim with CPO services must only be submitted after the end of the month that the services were performed.

Home Health Certification and Recertification

  • Certification: date of service should be billed as the date the physician completes and signs the plan of care.
  • Recertification: date of service should be billed as the date the physician completes the review.

Physician End-Stage Renal Disease (ESRD) Services

  • For patients beginning dialysis: date of service is the date of their first dialysis through the last date of the calendar month.
  • For continuing patients: date of service is the first through last date of the calendar month.
  • For transient or less than a full month patients: bill on a per diem basis. Date of service is the date of responsibility for the patient by the billing physician. This also includes when a patient dies during the calendar month.

Transitional Care Management

Transitional Care Management, or TCM, are services provided for a patient when discharged from an appropriate facility who requires moderate to high-complexity medical decision making.

  • Date of service should be billed as the date the practitioner completes the required face-to-face visit.

Clinical Laboratory Services

The general rule for clinical laboratory services is to bill the date of service as the date the specimen was collected. In cases where collection lasts more than one calendar day, the date of service is the date the collection ended.

3 Exceptions:

1. Date of service for tests or services performed on stored specimens

If specimen were stored less than or equal to 30 days, the date of service that should be billed is the date the test or service was performed, only if:

  • The test or service is ordered by the physician at least 14 days following the date of the patient’s discharge from the hospital
  • The specimen was collected while the patient was undergoing a hospital surgical procedure
  • It would have been medically inappropriate to collect the sample other than during the procedure for which the patient was admitted
  • The results of the test or service do not guide treatment provided during the hospital stay
  • The test or service was reasonable and medically necessary for treatment of an illness

If the specimen was stored for more than 30 days, the date of service is the date the specimen was obtained from storage.

2. Date of service for chemotherapy sensitivity tests or services performed on live tissue

Date of service should be the date the test was performed only if:

  • The decision of the specific chemotherapy agent to test is made at least 14 days after discharge
  • The specimen was collected while the patient was undergoing a hospital surgical procedure
  • It would have been medically inappropriate to collect the sample other than during the procedure for which the patient was admitted
  • The results of the test or service do not guide treatment provided during the hospital stay
  • The test or service was reasonable and medically necessary for treatment of an illness

3. Date of service for advanced diagnostic laboratory tests (ADLTs) and molecular pathology tests

Date of service for ADLTs or molecular pathology tests should be the date the test was performed only if:

  • The test was performed following a hospital outpatient’s discharge from the hospital outpatient department
  • The specimen was collected from a hospital outpatient during an encounter
  • It was medically appropriate to collect the sample from the hospital outpatient during the hospital outpatient encounter
  • The results of the test do not guide treatment provided to the patient during hospital outpatient encounter
  • The test was reasonable and necessary for treatment of an illness

Home Prothrombin Time (PT/INR) Monitoring

  • For procedure code G0248, the initial demonstration use of home INR monitoring and instructions for reporting, date of service is the date the demonstration and instructions are given face-to-face with the patient.
  • For procedure code G0249, the provision of test materials and equipment for home INR monitoring, date of service is the date the materials and equipment are given to the patient.
  • For procedure code G0250, the physician review, interpretation, and patient management of home INR testing, the date of service is the date of the fourth test interpretation (this service is only payable once every four weeks).
  • For procedure code 93793, physician interpretation and instructions, the date of service is the date of the review.

Cardiovascular Monitoring Services

There are many different CPT codes that describe cardiovascular monitoring services – some of these are professional components (PC) and some are technical components (TC).

  • If the service includes physician review and interpretation, the date of service is the date the physician completes this activity.
  • If the service is a technical service, the date of service is the date the monitoring is completed.

Psychiatric Testing and Evaluation

There are some situations in which psychiatric or psychological and neuropsychological tests require multiple sessions over different dates. For this situation, the date of service is the date that the service is completed. The documentation submitted on the claim should reflect that the service began on one day and concluded on another day.

Surgical Services

For billing surgical services, follow the global surgery rules. All services considered to be part of the global package, including follow-up visits, are considered to have occurred on the same date as the surgery was performed – they are not submitted separately.

  • Surgeons who perform surgery and then transfer post-operative care to another practitioner will submit their claim with the date of service as the date the surgery was performed, along with the Modifier 54.
  • If the surgeon keeps responsibility for the patient for some post-operative care, they submit the date of surgery, surgery procedure code with Modifier 55, and last date of responsibility indicated in Item 19 or the electronic equivalent.
  • The practitioner receiving the transfer of the patient will submit their services using the surgical procedure code with Modifier 55, and the date of service is the date the surgery was performed. If they receive the patient on a day other than the date the patient was discharged, they include the date care began on Item 19 or the electronic equivalent.

Maternity Benefits

  • The date of service for all expenses, including preoperative/prenatal examinations, testing, and post-operative/postnatal services, will be billed with the date of delivery.

Services Which Transpire Over to Another Calendar Date

These are services that start on one date and conclude on another date. They cannot be submitted until completed, and unless otherwise noted, should be billed using either the date the service began or the following day that the service was completed.

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