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December 20, 2018

Correct Date of Service for Specific Services

Provider Types Affected

This article is applicable to physicians, non-physician practitioners, and others submitting claims for reimbursement for Medicare Part B services.

Provider Action Needed

Stop – Impact to You

Physicians and non-physician practitioners need to identify the correct date of service for the services they provide to a Medicare patient.

Caution – What you need to know

Most services must be billed to Medicare reflecting the exact date the services were performed for or provided to the patient, with some exceptions.  This article will discuss some of the situations where there have been questions from the provider community.

Go - What you need to do

Providers need to determine the Medicare rules and regulations concerning the date of service and submit claims appropriately.

Background

The information below will not provide all the billing instructions for the individual services. This information concentrates on the date(s) of service to submit when billing for these services.  If you are providing these services, please take advantage of the information available on the CMS website in addition to your Medicare Administrative Contractor’s web portals.  Generally, expenses are considered to have been incurred on the date the beneficiary received the item or service, regardless of when it was paid for or ordered. Any exceptions are discussed below.

CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15External PDF, Section 20

Radiology Services

Typically, radiology services have two separate components: a professional and technical component. These services will have a PC/TC indicator of “1” on the Medicare Physician Fee Schedule Relative Value File. The technical component is billed on the date the patient had the test performed.  When billing a global service, the provider can submit the professional component with a date of service reflecting when the review and interpretation is completed or can submit the date of service as the date the technical component was performed.  This will allow ease of processing for both Medicare and the supplemental payers.  If the provider did not perform a global service and instead performed only one component, the date of service for the technical component would be the date the patient received the service and the date of service for the professional component would be the date the review and interpretation is completed.

Medicare Physician Fee Schedule Relative Value FileExternal Website

Surgical and Anatomical Pathology

Surgical and anatomical pathology services may have two components; a professional and a technical component.  These services will have a PC/TC indicator of “1” on the Medicare Physician Fee Schedule Relative Value File.  The technical component is billed on the date the specimen was collected.  This would be the surgery date.  When billing a global service, the provider can submit the professional component with a date of service reflecting when the review and interpretation is completed or can submit the date of service as the date the technical component was performed.  This will allow ease of processing for both Medicare and the supplemental payers.  If the provider did not perform a global service and instead performed only one component, the date of service for the technical component would the date the patient received the service and the date of service for the professional component would be the date the review and interpretation is completed.

When the collection spans two calendar dates, then the date of service is the date the collection ended. There are three exceptions:

Stored specimens – In the case of a test/service performed on a stored specimen, if a specimen was stored for less than or equal to 30 calendar days from the date it was collected, the DOS of the test/service must be the date the test/service was performed only if:

  • The test/service is ordered by the patient’s 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 be medically inappropriate to have collected the sample other than during the hospital procedure for which the patient was admitted;
  • The results of the test/service do not guide treatment provided during the hospital stay; and
  • The test/service was reasonable and medically necessary for treatment of an illness.

If the specimen was stored for more than 30 calendar days before testing, the specimen is considered to have been archived and the DOS of the test/service must be the date the specimen was obtained from storage.

Medicare Physician Fee Schedule Relative Value FileExternal Website

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 16External PDF, Section 40.8.

Chronic Care Management (CCM)

CCM is a time-based service providing care for the patient monthly.  The non-complex service can be billed to Medicare when the time threshold for the procedure code has been met and documented in the patient’s records.  Services would continue as medically necessary throughout the month.  The date of the time completion is the date of the service. For complex CCM, once the requirements are met, the date of service is the end of the calendar month.  CCM time requirements would begin at the start of the next month.

CCMExternal PDF Questions and Answers

CCM FACTExternal PDF Sheet

Care Plan Oversight (CPO)

CPO is physician supervision of a patient receiving complex and/or multidisciplinary care as part of Medicare covered services provided by a participating home health agency or Medicare approved hospice.  This service provides physician supervision of a patient involving 30 minutes or more providing specified services.  The claim for CPO must not include any other services and is only billed after the end of the month in which CPO was provided.  The date of service can be the last date of the month or the date in which at least 30 minutes of time is completed.

CMS IOM 100-04, Medicare Claims Processing Manual, Chapter 12External PDF, Section 180.1.A

CMS IOM 100-02, Medicare Benefit Policy Manual, Chapter 15External PDF, Section 30.G

Home Health Certification and Recertification

The date of service for the Certification is the date the physician/non-physician practitioner (NPP) completes and signs the plan of care.  The date of the Recertification is the date the physician/NPP completes the review.

CMS IOM 100-04, Medicare Claims Processing Manual, Chapter 12External PDF, Section 180.1.B

CMS IOM 100-01, Medicare General Information, Entitlement, and Eligibility Manual, Chapter 4External PDF, Section 30

CMS IOM 100-02, Medicare Benefit Policy Manual, Chapter 7External PDF, Section 30.2.6

Physician End-Stage Renal Disease Services

A physician may provide monthly or daily oversight of a patient on dialysis with End-Stage Renal Disease (ESRD).  The date of service for a patient beginning dialysis is the date of their first dialysis through the last date of the calendar month.  For continuing patients, the date of service is the first through the last date of the calendar month.  For transient patients or less than a full month service, these can be billed on a per diem basis.  The date of service is the date of responsibility for the patient by the billing physician.  This would also include when a patient’s dies during the calendar month.  When submitting a date of service span for the monthly capitation procedure codes, the day/units should be coded as “1”.

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 8External PDF, Section 140.

Transitional Care Management (TCM)

TCM services are a 30-day service provided when a patient is discharged from an appropriate facility and requires moderate or high-complexity medical decision making. The date of service is the date the practitioner completes the required face-to-face service.

Transitional Care Management Fact SheetExternal PDF

TCM Frequently Asked QuestionsExternal PDF

Clinical Lab Services

Generally, the date of service is the date the specimen was collected.  If the specimen is collected over a period that spans two calendar dates, then the date of service must be the date the collection ended.  This would include the collection fee, services provided in a physician laboratory, in a clinical laboratory, and/or a reference laboratory.

There are three exceptions to the general date of service rule for laboratory tests:

  • The date of service for tests/services on a stored specimen
  • The date is the date performed if:
    • Ordered by the patient’s physician at least 14 days following the date of patient discharge from the hospital;
    • Specimen was collected while the patient was undergoing a hospital surgical procedure;
    • It would have been medically inappropriate to have collected the sample other than during the hospital procedure for which the patient was admitted;
    • The results do not guide treatment provided during the hospital stay; and
    • Test was reasonable and necessary for treatment of an illness
  • The date of service for chemotherapy sensitivity tests/services performed on live tissue
  • The date is the date performed if:
    • The decision as to the specific chemotherapy agent to test is made at least 14 days after discharge;
    • Specimen was collected while the patient was undergoing a hospital surgical procedure;
    • Medically inappropriate to have collected the sample other than during the hospital procedure for which the patient was admitted;
    • Results of the test/service do not guide treatment provided during the hospital stay; and
    • Test/service was reasonable and medically necessary for treatment of an illness
  • The date of service for advanced diagnostic laboratory tests and molecular pathology tests
  • The date must be the date performed if:
    • Test performed following hospital outpatient’s discharge from the hospital outpatient department;
    • Specimen was collected for hospital outpatient during an encounter;
    • Medically appropriate to collect the sample from the hospital outpatient during the hospital outpatient encounter;
    • Results of the test do not guide treatment provided during the hospital outpatient encounter; and
    • Test was reasonable and necessary for the treatment of an illness

CMS IOM 100-04, Medicare Claims Processing Manual, Chapter 16External PDF, Section 40.1

Home Prothrombin Time (PT/INR) Monitoring

There are several procedure codes applicable to this service.  The G0248 describes the initial demonstration use of the home INR monitoring and instructions for reporting given in a face-to-face setting with the patient.   The date of service is the date of the face-to-face meeting.

The G0249 describes the provision of test materials and equipment for home INR monitoring.  The date of service is the date the items are provided to the patient.

The G0250 describes the physician review, interpretation, and patient management of the home INR testing. This service is payable only once every four weeks.  The date of service is the date of the fourth test interpretation.

For 2018, there is also code 93793 describing the physician interpretation and instructions.  The appropriate date of service is the date of the review.

CMS IOM 100-04, Medicare Claims Processing Manual, Chapter 32External PDF, Section 60.5

Cardiovascular Monitoring Services

There are many different procedure codes that represent cardiovascular monitoring services.  These can be identified as professional components, technical components, or a combination of the two.  Some of these monitoring services may take place at a single point in time, others over 24 or 48 hours, or over a 30-day period.  The determination of the date of service is based on the description of the procedure code and the time listed.  When the service includes a physician review and/or interpretation and report, the date of service is the date the physician completes that activity.  If the service is a technical service, the date of service is the date the monitoring concludes based on the description of the service.  For example, if the description of the procedure code includes 30 days of monitoring and a physician interpretation and report, then the date of service will be no earlier than the 30th day of monitoring and will be the date the physician completed the professional component of the service.

CMS IOM 100-03, National Coverage Determinations (NCD) Manual, Chapter 1External PDF, Section 20.8.1.1

Psychiatric Testing and Evaluations 

In some cases, for various reasons, psychiatric evaluations (90791/90792) and/or psychological and neuropsychological tests (96101/96172) are completed in multiple sessions that occur on different days.  In these situations, the date of service that should be reported on the claim is the date of service on which the service (based on CPT code description) concluded. Documentation should reflect that the service began on one day and concluded on another day (the date of service reported on the claim.)  If documentation is requested, medical records for both days should be submitted.

CMS IOM 100-04, Medicare Benefit Policy Manual Chapter 15External PDF, Section 80.2

Surgical Services
Medicare’s payment for most surgical services is made using the global surgery package rules.  All services considered to be part of the global package including follow up visits are considered to have occurred on the same day as the surgical service and are not submitted separately.  Surgeons who perform the surgery and then transfer post-operative care to another practitioner will submit their claims using the date of the surgery as the date of service along with Modifier 54.  If the surgeon keeps responsibility for the patient for some of the post-operative care, he/she would submit the date of the surgery, the surgery procedure code with Modifier 55, and the last date of responsibility indicated in Item 19 or the electronic equivalent.  The practitioner receiving the transfer of care will submit his/her post-operative services using the surgical procedure code with Modifier 55 with the date of the surgery as his/her date of service.  If the practitioner receives the patient on a date other than the discharge date from an inpatient stay, Item 19 or the electronic equivalent will include the date care began.

CMS IOM 100-04, Medicare Claims Processing Manual, Chapter 12External PDF, Section 40

Maternity benefits

All expenses incurred for surgical and obstetrical care including preoperative/prenatal examinations, testing, and post-operative/postnatal services are part of the maternity package and may be billed under the appropriate surgical code on the date of delivery or termination.  Charges the practitioner may impose that are not related to the delivery are incurred on the date furnished.

CMS IOM 100-02, Medicare Benefits Policy Manual, Chapter 15External PDF, Section 20.1.

Teaching physician Services

The date of service is the date the teaching physician either performed the service or the date they were with the resident during the critical or key aspects of the service. The most common example of services performed on a separate date is when the resident sees the patient late on the first date and the teaching physician sees them the following calendar date.

CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 12External PDF, Section 100.1.A Scenario 4

Services which transpire over to another calendar date

This category could include multiple types of services.  The service would be started on one day and concluded the following day.  The service cannot be submitted to Medicare until completed.  Unless otherwise notated, the billing entity can utilize either the date the service began or the following day when the service concluded.

NOTE:  This document was developed through the A/B Medicare Administrative Contractor (MAC) Provider Outreach & Education (POE) Collaboration Team.  This join effort ensures consistent communication and education throughout the nation on a variety of topics and will assist the provider and physician community with information necessary to submit claims appropriately and receive proper payment in a timely manner.

Hyperlink Table

Embedded Hyperlink

Complete URL

CCM Fact Sheet

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/ChronicCareManagement.pdfExternal PDF

CCM Questions and Answers

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/Payment_for_CCM_Services_FAQ.pdfExternal PDF

Medicare Benefit Policy Manual, Chapter 15

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdfExternal PDF

Medicare Benefit Policy Manual, Chapter 7

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c07.pdfExternal PDF

Medicare Claims Processing Manual, Chapter 12

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c12.pdfExternal PDF

Medicare Claims Processing Manual, Chapter 16

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c16.pdfExternal PDF

Medicare Claims Processing Manual, Chapter 32

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c32.pdfExternal PDF

Medicare Claims Processing Manual, Chapter 8

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c08.pdfExternal PDF

Medicare General Information, Eligibility, and Entitlement Manual, Chapter 4

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/ge101c04.pdfExternal PDF

Medicare National Coverage Determinations (NCD) Manual, Chapter 1

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/ncd103c1_part1.pdfExternal PDF

Medicare Physician Fee Schedule Relative Value File

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Relative-Value-Files.htmlExternal Website

TCM Frequently Asked Questions

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/FAQ-TCMS.pdfExternal PDF

Transitional Care Management Fact Sheet

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/Transitional-Care-Management-Services-Fact-Sheet-ICN908628.pdfExternal PDF

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