The Center for Medicare and Medicaid Services (CMS) recently announced a new place of service (POS) rule that every practice needs to know.
As per the CMS’s Transmittal 2435 elaborating the new rule, the POS code you report for your physician should reflect the “setting in which the beneficiary received the face-to-face service.” There are however exceptions to this rule, so be sure to read the rule in its entirety and pay attention to each element.
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Important dates: The effective date is October 1, 2012—this is a delay from the previous implementation date of April 1.
Under CMS’s announced rule, providers performing the PC [professional component] of interpretation of tests must use the POS where the face-to-face service—test—was performed, i.e. outpatient facility, ASC [ambulatory surgical center], etc.
In you have any doubt about whether the rule applies to diagnostic imaging, CMS clearly states in MLN Matters article 7631 that if the patient has an imaging exam at one site and the physician interprets the exam at his office, the POS should reflect where the patient had the exam. You should not base your POS code on where the physician provided the interpretation.
For physician claims, you must decide whether to report office POS 11 for where the physician provided the service or POS 22 for the outpatient hospital where the patient had the exam. Under the new rule, you should report POS 22 because that’s where the patient had the outpatient exam.
Caution: Although you designate the outpatient...
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