In response to the American College of Radiology (ACR) and Radiology Business Management Association (RBMA), the Medicare Administrative Contractor (MAC), Novitas Solutions Inc., has revised its date of service (DOS) FAQ now enabling medical imaging providers in more than 14 states and cities to bill it for Medicare services using either the date of the technical exam or the date of professional interpretation as the DOS.
Novitas contacted the ACR on July 21, 2017 to announce revised DOS language that allows providers to select their preferred date of service. The Novitas FAQ for Part B Billing includes a revised question 13 on the DOS.
Novitas is responsible for local Medicare coverage policies and claims processing in Jurisdiction L and Jurisdiction H. Jurisdiction L covers Pennsylvania, New Jersey, Maryland, Delaware and the Washington, D.C., metro area as well as Arlington and Fairfax counties in Virginia, the city of Alexandria, VA, the District of Columbia, and Montgomery and Prince George’s counties in Maryland. Jurisdiction H spans Colorado, Oklahoma, New Mexico, Texas, Arkansas, Louisiana, Mississippi, the federal Indian Health Service and Veterans Affairs health facilities.
In a joint comment letter to Novitas, the ACR and RBMA emphasized that defining DOS as the date of the professional component is problematic because of variations in the time between imaging and interpretation. The ACR and RBMA proposed language on DOS modeled after the National Government Service’s (NGS) policy, a neighboring state and jurisdiction of Novitas and a MAC.
The ACR supports a policy that accepts both dates of service because this approach recognizes the complexity of the current billing practices and varied information systems. Historically, the ACR, RBMA and other key stakeholders have held that the DOS should be the date the technical component of an imaging procedure is performed for complex reasons outlined in the ACR and RBMA comment letter under the section titled CMS’s DOS Guidance. For these reasons, the Centers for Medicare & Medicare Services (CMS) rescinded its DOS policy in February 2010. Facility and billing systems have always used the date of performance of the technical exam component as the DOS.
Although less optimal, allowance of both date of the technical service and date of the interpretation are important to accept as the DOS until CMS issues its own DOS national guidance. The ACR applauds Novitas’s efforts to provide assurance to radiology providers and their practices on DOS based on the standing radiology practice.
Identifying DOS for medical imaging procedures is complicated by their discrete professional and technical components, and the use of sophisticated technology further confounds this issue. Providers use sophisticated automated systems for coding, billing and payment processing. These systems interface with the health care facility’s radiology information systems (RIS), picture archiving and communication systems (PACS) and hospital or radiology information systems (HIS/RIS). The date an imaging exam is performed — a specific time that is synonymous with the date of the technical component — is the common denominator and the current standard practice across these systems. According to a February 2013 RBMA “Hot Topics” poll, 89 percent of respondents, who bill for the professional component only, reported using the technical service date as the DOS. All respondents who use global and split billing said they used the technical service date.
The date of the performance of the technical exam remains the preferable DOS and represents long-standing practice in radiology. However, in this interim period without national guidance, we recommend all MACs allow both the date of the technical service and date of the professional interpretation for DOS.