Several Medicare Administrative Contractors, including Novitas Solutions, have in the past instructed imaging providers to use the date of the interpretation as the date of service for the professional component of the imaging exam. This policy has created major logistical challenges, since providers have traditionally reported the professional component with the date the exam was performed, not the date of the interpretation. This policy has also limited imaging providers' ability to bill globally unless the exam is interpreted on the same day it is performed.
In response to a request from the American College of Radiology and the Radiology Business Management Association, Novitas has now reversed its policy and will permit providers to use either the date of the exam or the date of the interpretation as the professional component date of service. A Frequently Asked Question from Novitas reads:
What date of service should I report when completing a diagnostic interpretation on a different date from the actual test?
We recognize that providers do not always perform the professional component on the same date as the technical component. Many providers prefer to submit a claim with a date of service that reflects the day the professional component was performed, while others prefer to use the date of the technical component as the date of service for their professional component.
There is no policy from CMS that requires billing to be one way or the other. Since there is no specific policy, regulation, or other mandate from CMS on this issue, we will leave which date of service is billed for the professional component up to the provider.
This policy applies to both of the Novitas jurisdictions (JL and JH), and it mirrors the DOS policy of National Government Services in Jurisdiction K.
For more information, please see the ACR Advocacy in Action eNews, 7 /28/17.