Forget What I Said – Medicare Date of Service Rule May Not Require Separate Line-Item Claims for Pathology Services

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In our June 12, 2009 Payment Matters, we commented on a recent change in the Medicare Claims Processing Manual (MCPM) that would require claims for physician pathology services to be billed as separate line items if the two components had a different Date of Service (DOS). The MCPM change was made by Transmittal 1744, "Manual Update to Include Billing Instructions for Professional Component (PC) and Technical Component (TC) in Regards to One Line Global Billing for Pathology Services."

CMS recently rescinded Transmittal 1744 without comment. Presumably, this means that, ordinarily, when the technical component and professional component of a pathology service are performed by the same physician or independent laboratory, a global bill can be submitted to Medicare even if the two components have a different DOS. Given the lack of CMS guidance, questions regarding this issue should now be addressed to the carrier or other Medicare payment contractor.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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