CMS Revises Place of Service Policy for Teleradiology, Again

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According to Centers for Medicare and Medicaid Services’ Transmittal 2563, its clarified place of service (POS) policy is now scheduled for implementation on April 1, 2013. The policy seeks to resolve confusion arising from how to bill for diagnostic tests in teleradiology situations where the technical component (TC) is furnished in one place and the radiologist’s read or professional component (PC) is furnished in another place. It seems simple enough. However, arriving at exactly the right policy has proven to be tricky. CMS issued POS policy notices from March 29, 2012 (Transmittal 2435), and September 28, 2012 (Transmittal 563), were both later rescinded. As things currently stand, the place of service code should be the one for where the actual face-to-face patient encounter took place and the TC was provided. In addition, CMS has provided guidance for situations involving global payment arrangements, differences in inpatient and outpatient billing, and cases where the physician might be reading from somewhere other than his or her usual medical office, such as from a hotel while attending a conference. The American College of Radiology summarizes the now 40 pages of instructions succinctly here.