CLMA’s Medicare Billing Issues Committee (MBIC) has been working to get a clarification and seeking a further delay in the implementation of the Place of Service (POS) requirements issued by CMS earlier this year. In Change Request 7631 (transmittal R2435CP) titled "Revised and Clarified POS Coding Instructions.”, CMS made some changes to what POS code laboratories used on claims for tests paid under the Medicare Physician Fee Schedule, changes that if implemented as written, would have imposed financial challenges for laboratories and increased the risk for compliance violations. We are happy to report that as a result of questions we have been asking of CMS regarding this change, we have received an indication that CMS has heard our concerns and is re-examining the issue. Click here to learn more.

In an e-mail response to questions posed by the MBIC, Mr. Craig T. Dobyski, Health Insurance Specialist for CMS’ Center for Medicare Hospital and Ambulatory Policy Group Division of Practitioner Services said, "CMS is having discussions about addressing place of service billing issues for pathology and laboratory services through additional instructions and revising the effective date for implementing POS policies. Please check the CMS website for any new transmittals regarding POS policies.”

We believe this is a positive message meaning that we can expect a delay in implementation at the minimum and more information and instruction. We are monitoring the CMS transmittal website daily and as soon as we see any transmittals concerning changes to this policy, we will let you know. For more information on the issue discussed in this article, see the CMS transmittal R2435CP posted on the CMS website at http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2012-Transmittals-Items/R2435CP.html.