October 31, 2009

ACR Radiology Coding Source™ September-October 2009

CMS Recommends New Guidelines for POS and DOS

The Centers for Medicare and Medicaid Services (CMS) issued Transmittal #1823 which describes how to appropriately select the correct place of service (POS) and date of service (DOS) codes when reporting professional (interpretation) and technical components of diagnostic tests. CMS noted that the POS code for the interpretation should reflect the actual place where the service was provided, and that the DOS for the interpretation of diagnostic images should designate the date of interpretation. While CMS previously issued the POS guidelines to submit the ZIP code for the location of the service, the DOS guideline to use the date of interpretation is new. 

Because the ACR and Radiology Business Management Association have concerns with the lack of operational preparedness of the industry to implement these new guidelines, they will request that CMS delay the implementation of this transmittal by six months and allow the specialty societies to provide input to address our concerns and to facilitate the adoption of the new definitions within our organizations. 

The ACR will post CMS’ response to the ACR and RBMA request for a six-month implementation delay on the ACR Web site under What’s New as soon as it is received. 

For detailed information on the CMS POS and DOS transmittal go to the CMS Web site.