October 06, 2017

CMS Rescinds Guidance on Radiology DOS Billing

On October 2, 2017 the Centers for Medicare and Medicaid Services (CMS) rescinded its guidance on radiology date of service (DOS) billing that required the separate reporting of date of service information for the professional and technical components of radiology services.

The rescindment of transmittal (SE17023), originally issued on September 19, 2017, was announced in an article on CMS’ Medicare Learning Network (MLN). The article claimed its guidance did not “present any new or revised Medicare policy. Instead, (this) article reiterates current Medicare policy.” However, the Medicare Claims Processing Manual currently contains no language requiring the separate reporting of date of service information for the professional and technical components of radiology services.

CMS issued similar DOS guidance in 2009. The ACR and allied associations submitted a letter to CMS in response recommending that 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 CMS later rescinded their 2009 guidance, and there remains no national policy in place for radiology date of service.

In the notice rescinding SE17023, CMS further states that the guidance detailed in SE17023 may be reissued at a later date.

The ACR, in concert with stakeholders in the Radiology Business Management Association (RBMA), is preparing a letter reiterating our position, and we will seek further opportunities to meet with CMS on this issue.

Please direct your questions to Dominick Parris (djparris@acr.org ), an economics policy analyst in the ACR’s Department of Economics and Health Policy.