Look Out for CMS’s Place of Service Code Changes

The presidential election is center stage at the moment, and rightly so. For physicians, the outcome of that election may have profound implications for how our business is conducted, how the system we’ll be working in may change, and how and how much we’ll all be paid.

Just because there’s a big election with policy implications in the offing doesn’t mean there aren’t changes afoot in small policies and administration. And some of those may have as big an impact or bigger in the short term.

CMS has become ever more active in recent months, apparently in an effort to constrain costs however it can. Investigations for fraud are in the news regularly, and RACs are increasingly evident in the workplace, in no small part evaluating independent testing facilities for compliance. Another recent policy change was announced that may affect radiology outpatient billing and potentially put radiologists at risk from CMS as well. Starting in April of 2013, CMS says it will strictly require place of service (POS) codes for outpatient services to match the POS for the technical component of the service, including for imaging.

If the technical component is performed in what they call an outpatient hospital, both the technical and professional components have to be billed with that outpatient hospital POS, regardless of where the study is read. That means that if you are in a hospital-based or affiliated practice, and you are reading for an outpatient facility of the hospital, you need to know what place of service code they are using.

Just another billing office compliance issue, you might say? Not so fast. If you bill your interpretation with a non-facility POS code (such as “office”), it means a much higher reimbursement from CMS than that which is allowed for the professional component associated with an outpatient hospital service. So for practices that do a large volume of reading for outpatient hospital-based facilities - and aren’t in compliance with the correct POS - you can expect a big hit to the bottom line from your Medicare payments in 2013.

Keep a close eye on the election, but don’t forget that CMS administration is not waiting on the results to make or amend its policies, to trim payments to us.