January 31, 2019

CMS Issues Guidance on DOS for Radiology Services

On January 24, 2019, the Centers for Medicare & Medicaid Services (CMS) reissued MLN Matters article SE17023, Guidance on Coding and Billing Date of Service on Professional Claims.

The article provides information regarding required dates of service (DOS) for radiology and other Medicare Part B services. It also describes options for reporting the DOS in a global billing of a radiology service as either the date when the technical component (TC) is performed or the date when the professional service (PC) is performed. CMS further instructs providers that the date of service reported when the TC and PC are billed separately should be the dates each was performed, respectively.

SE17023 was originally issued on September 19, 2017, and provided guidance requiring the separate reporting of date of service information for the professional and technical components of radiology services, but this transmittal was rescinded shortly afterward on October 2, 2017.

CMS issued similar DOS guidance in 2009. The American College of Radiology (ACR), Radiology Business Management Association (RBMA) and allied associations submitted a letter to CMS in response, recommending the DOS for professional interpretations should be the date when the technical component was performed. Numerous examples detailing the advantages of this approach were cited with the ACR’s recommendation.

CMS later rescinded its 2009 guidance, leaving no national policy to define radiology date of service.

The ACR expects to continue its work with RBMA in developing communications with CMS on DOS issues. Questions should be directed to Dominick Parris (djparris@acr.org) in the ACR Economics and Health Policy Department.