Place of Service Changes for Hospital-Based Pathologists (4/1/2012)
CMS has revised and clarified its national policy on Place of Service (POS) coding guidelines due to the Office of the Inspector General’s (OIG) findings of incorrect POS reporting.; this new policy will take effect on April 1, 2012.
The POS coding guidelines apply to all services paid via the Medicare physician fee schedule (MPFS). When billing the Professional Component, Technical Component, or Global charge for a clinical laboratory test or pathology procedure, one must bill with the POS based upon the physical location of the patient during specimen collection.
This change only affects your hospital’s outreach work performed for non-hospital patients.
Your billing company receives POS information from your facility’s electronic charge file. For this reason, you are encouraged to work with your facility to ensure your billing company receives the proper documentation to bill appropriate POS.
We have prepared a few specific examples to review with our clients and would be happy to discuss these specific examples should you have questions or concerns
Please click here to read CMS transmittal 2407 (Change Request 7631, entitled Revised and Clarified Place of Service (POS) Coding Instructions): https://www.cms.gov/transmittals/downloads/R2407CP.pdf. Do not hesitate to contact us with any questions, comments, or concerns you may have. Our team of certified coders is working closely with our In-House Counsel, outside counsel, and organizations representing pathologists’ interests to clarify questions related to this transmittal, and we will advise should there be any additional information, or change to the implementation date.