The Centers for Medicare & Medicaid Services (CMS) has issued new guidance on what date of service (DOS) should be billed for various Medicare Part B services.  For radiology services, CMS offers the option of reporting the DOS of either the date when the radiology study was performed on the patient or the date of the professional interpretation when a “global” claim is submitted for payment for both components. When the technical component (TC) or professional component (PC) of the service is billed separately, however, CMS now directs that the DOS on the claim for the TC must be the date the imaging study was performed and the DOS on the claim for the PC must be the date the professional interpretation is performed.

The radiology industry is disappointed by this guidance, since it would not allow the TC and PC be the same DOS, even when billed separately. Radiology industry billing professionals are concerned that reporting multiple DOS on claims for the separate components can create considerable confusion on the part of patients.  Furthermore, payers adjudicating claims can experience difficulty linking the TC and PC components when they report different dates of services. This is particularly concerning since the place of service indicated for the professional component on the claim may not be the same location as the technical component service.  We can expect future efforts to encourage CMS to revise this policy to facilitate billing for radiology services.