Place-of-service billing rules require attention to professional component location

Newly implemented place-of-service (POS) rules from the Centers for Medicare and Medicaid Services contain instructions for reporting the location where the professional component (PC) of radiologic services are provided. These new rules, which took effect April 1, have significant billing implications for radiology practices, according to an article published in the May issue of the Journal of the American College of Radiology.

Under the new rules, it is especially important that practices understand it is not appropriate to bill all claims as global without considering where the PC was provided, according to Ezequiel Silva III, MD, University of Texas Health Science Center at San Antonio.

Billing claims submitted to Medicare require two pieces of location information for radiologic services, explained Silva. A POS code identifies where a patient received a face-to-face encounter, and in radiology the POS code should reflect where the technical component (TC) of a service was provided.

The other piece of information is a physical address with zip code to determine the payment locality. Silva wrote that the address should reflect where the PC was provided, and in cases where an interpretation is provided in an unusual location, such as a hotel room, the address should indicate the Medicare-enrolled location where the radiologist most commonly practices.

For global billing to apply, the TC and PC of a radiologic service muse be furnished by the same physician or supplier entity and within the same payment locality, according to Silva. In these cases, a single claim for both the TC and PC can be submitted. However, if the different components of a services are provided by different physicians or in different localities, global billing is prohibited.

“Remote interpretations, such as with teleradiology, frequently involve different payment localities for the TC versus the PC. As such, global billing is not an option,” wrote Silva. When a remote interpretation is provided, the POS code for the PC claim is still where the TC was received, but the physical address on the claim form should be where the interpretation was provided, clarified Silva.

Silva advised radiologists to seek guidance from the Medicare administrative contractor for their locality if questions arise.