CMS Issues New POS Guidance

February 21, 2012

The Centers for Medicare & Medicaid Services (CMS) has provided new Place of Service (POS) guidance in Change Request (CR) 7631 (Transmittal 2407) effective on April 1, 2012.  This new POS guidance is the result recommendations made by The Society of Nuclear Medicine, as well as the Radiology Business Management Association (RBMA), the Healthcare Billing & Management Association (HBMA), the American College of Radiology (ACR), the Medical Group Management Association (MGMA), and AHRA: the Association for Medical Imaging Management.

CMS States: This CR revises and clarifies national policy for POS code assignment. Instructions are provided regarding the assignment of place of service (POS) for all services paid under the Medicare Physician Fee Schedule and for certain services provided by independent labs. In addition to establishing a national policy for the correct assignment of POS codes, instructions are provided for the interpretation or professional component (PC) and the technical component (TC) of diagnostic tests.

Although these clarifications are a welcome and needed change, there remain two areas that require further investigation:

  • Whether the carrier jurisdiction rules (Claims Process Manual, Ch. 1, Sec. are superseded by zip code billing process
  • The impact on global billing since billing the PC and TC components together is now possible only when the TC supplier and the physician who provides the interpretation service are the same.  

CMS made these changes following SNM’s recommendations and had stated in the past that Transmittal 1873 would be replaced, “pending further policy clarification on date of service and place of service reporting for the interpretation of diagnostic tests”.

SNM Comments letters regarding this issue can be found below.  SNM will continue to monitor these issues as well as any others that might result from Transmittal 2407.