CMS 1500 Claim Form

Date of Service on CMS-1500 Billing

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Overview

This article will assist Medicare Part B providers including physicians, nonphysician practitioners and others, how to report the correct date of service on the CMS-1500 claim form, and its electronic equivalent, for reimbursement of Medicare Part B services. Most services, with some exceptions, must be billed to Medicare reflecting the exact date the services were performed on, or provided to, the patient. The CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 20, explains that expenses are considered to have been incurred on the date the beneficiary received the item or service, regardless of when it was paid for or ordered.

In the following sections we provide answers to the most common date of service questions received from the NGS provider community.

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Radiology Services

Radiology services have two separate components, the professional component and the technical component. These services have a PC/TC indicator of “1” on the Medicare Physician Fee Schedule Relative Value File. They can be billed globally or individually for each component.

  • When billing a radiology service globally, the provider may use the date of service based on the professional component with the date of service reflecting when the review and interpretation is completed, or they may use the date of service as the date the technical component was performed. This will allow ease of processing for both Medicare and the supplemental payers.
  • When the provider does not perform a global service and performed only one component, the date of service for the technical component is the date the patient received the service and the date of service for the professional component is the date the review and interpretation is completed.

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Surgical and Anatomical Pathology

Surgical and anatomical pathology services have two components; a professional and a technical component. These services will have a PC/TC indicator of “1” on the Medicare Physician Fee Schedule Relative Value File. They can be billed globally or individually for each component.

  • When billing a pathology service globally, the provider may use the date of service based on the professional component with the date of service reflecting when the review and interpretation is completed, or they may use the date of service as the date the technical component was performed. This will allow ease of processing for both Medicare and the supplemental payers.
  • When the provider does not perform a global service and performed only one component, the date of service for the technical component is the date the patient received the service and the date of service for the professional component is the date the review and interpretation is completed.

Additional factors for pathology:

  • When the collection spans two calendar dates, use the date the specimen collected ended.
  • When a test is performed on a stored specimen (stored less than or equal to 30 calendar days), the date of service is the date the test was performed if:
    • The test is ordered at least 14 days following the patient’s discharge from the hospital;
    • Specimen was collected during a hospital procedure;
    • It would be medically inappropriate to have collected the same other than during the hospital procedure;
    • Results of the test do not guide treatment during the hospital stay;
    • The test was reasonable and medically necessary.

If the test is ordered on a specimen stored more than 30 days, the date of service for the technical service is the date the specimen is retrieved from storage. The professional component is billed on the date the physician provided the interpretation and report.

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Chronic Care Management

CCM is a time-based service providing care for the patient monthly. The noncomplex service can be billed to Medicare when the time threshold for the procedure code has been met and documented in the patient’s records. For complex CCM, the date of service is the end of the calendar month. CCM time requirements would begin at the start of the next month.

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Care Plan Oversight

CPO is physician supervision of a patient receiving complex and/or multidisciplinary care as part of Medicare covered services provided by a participating home health agency or Medicare approved hospice. Providers must provide physician supervision of a patient involving 30 or more minutes of the physician's time per month to report CPO services. The claim for CPO must not include any other services and is only billed after the end of the month in which CPO was provided. The date of service submitted on the claim can be the last date of the month or the date in which at least 30 minutes of time is completed.

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Home Health Certification and Recertification

The date of service for the certification is the date the physician completes and signs the plan of care. The date of the recertification is the date the physician completes the review.

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Physician End-Stage Renal Disease Services

A physician may provide monthly or daily oversight of a patient on dialysis with ESRD. For physicians billing the monthly capitation payment, the date of service is the first through the last day of the month. For transient or less than a full month service, these can be billed on a per diem basis. The date of service is the date of responsibility for the patient by the billing physician. This would also include when a patient’s dies during the calendar month. When submitting a date of service span for the monthly capitation procedure codes, the day/units should be coded as “1.”

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Transitional Care Management

TCM services are a 30-day service provided when a patient is discharged from an appropriate facility and requires moderate or high-complexity medical decision making. The date of service is the date the practitioner completes the required face-to-face service. Keep in mind, there are additional non-face-to-face services to be provided during the 30-day period.

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Clinical Lab Services

Generally, the date of service for clinical laboratory services is the date the specimen was collected. If the specimen is collected over a period that spans two calendar dates, the date of service is the date the collection ended. There are three exceptions to the general date of service rule for clinical laboratory tests:

  1. Date of service for tests/services performed on stored specimens

    In the case of a test/service performed on a stored specimen, if the specimen was stored less than or equal to 30 calendar days from the date it was collected, the date of service of the test/service must be the date the test/service was performed only if:
    • The test/service was ordered by the patient’s physician at least 14 days following the date of the patient’s discharge from the hospital;
    • The specimen was collected while the patient was undergoing a hospital surgical procedure;
    • It would be medically inappropriate to have collected the sample other than during the hospital procedure for which the patient was admitted;
    • The results of the test/service do not guide treatment provided during the hospital stay; and
    • The test/service was reasonable and necessary for the treatment of an illness.

If the specimen was stored for more than 30 calendar days before testing, the specimen is considered to have been archived and the date of service of the test/service must be the date the specimen was obtained from storage.

  1. Date of service for chemotherapy sensitivity tests/services performed on live tissue

    In the case of a chemotherapy sensitivity test/service performed on live tissue, the date of service of the test/service must be the date the test/service was performed only if:
    • The decision as to the specific chemotherapy agent to test is made at least 14 days after discharge;
    • The specimen was collected while the patient was undergoing a hospital surgical procedure;
    • It would be medically inappropriate to have collected the sample other than during the hospital procedure for which the patient was admitted;
    • The results of the test/service do not guide treatment provided during the hospital stay; and
    • The test/service was reasonable and medically necessary for treatment of an illness.
       
  2. Date of service for ADLTs and molecular pathology tests

    In the case of a molecular pathology test or a test designated by CMS as an ADLT under paragraph (1) of the definition of advanced diagnostic laboratory test in 42 CFR 414.502, the date of service must be the date the test was performed only if:
    • The test was performed following a hospital outpatient’s discharge from the hospital outpatient department;
    • The specimen was collected from a hospital outpatient during an encounter;
    • It was medically appropriate to collect the sample from the hospital outpatient during the hospital outpatient encounter;
    • The results of the test do not guide treatment provided during the hospital outpatient encounter; and
    • The test was reasonable and necessary for the treatment of an illness.

ADLTs and molecular pathology tests subject to the third exception to the general laboratory date of service rule are available on the Medicare Clinical Laboratory Fee Schedule web page under the Laboratory Date of Service Policy tab.

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Home Prothrombin (PT/INR) Time Monitoring

There are several procedure codes applicable to this service. The G0248 describes the initial demonstration use of home INR monitoring and instructions for reporting. The date of service is the date the demonstration and instructions for reporting are given in a face-to-face setting with the patient. G0249 describes the provision of test materials and equipment for home INR monitoring. The date of service is the date the test materials and equipment are given to the patient. G0250 describes the physician review, interpretation, and patient management of home INR testing. This service is payable only once every four weeks. The date of service is the date of the fourth test interpretation. For 2018, there is also code 93793 describing the physician interpretation and instructions. The appropriate date of service is the date of the review.

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Cardiovascular Monitoring Services

There are many different procedure codes that represent the cardiovascular monitoring services. These can be identified as professional components, technical components, or a combination of the two. Some of these monitoring services may take place at a single point in time, may take place over 24 or 48 hours, or may take place over a 30-day period. The determination of the date of service is based on the description of the procedure code and the time listed. When the service includes a physician review and/or interpretation and report, the date of service is the date the physician completes that activity. If the service is a technical service, the date of service is the date the monitoring concludes based on the description of the service. For example, if the description of the procedure code includes 30 days of monitoring and a physician interpretation and report, then the date of service will be no earlier than the 30th day of monitoring and will be the date the physician completed the professional component of the service.

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Psychiatric Testing and Evaluations

In some cases, for various reasons, psychiatric evaluations (90791/90792) are completed in multiple sessions that occur on different days. In this situation, the date of service that should be reported on the claim is the date of service on which the service (based on CPT code description) concluded. Documentation should reflect that the service began on one day and concluded on another day (the date of service reported on the claim). If documentation is requested, medical records for both days should be submitted.

Psychiatric testing when provided over multiple days based on the patient being able to provide information, is billed based on the time involved as described by the CPT and the last date of the test.

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Surgical Services

Medicare’s payment for most surgical services is made using the global surgery rules. All services considered to be part of the global package including follow-up visits, are considered to have occurred on the same day as the surgical service and are not submitted separately. Surgeons who perform the surgery and then transfer post-operative care to another practitioner will submit their claims using the date of the surgery as the date of service along with Modifier 54. If the surgeon keeps responsibility for the patient for some of the post-operative care, he/she would submit the date of the surgery, the surgery procedure code with Modifier 55, and the last date of responsibility indicated in Item 19 or the electronic equivalent. The practitioner receiving the transfer of care will submit his/her post-operative services using the surgical procedure code with Modifier 55 with the date of the surgery as his/her date of service. If the practitioner receives the patient on a date other than the discharge date from an inpatient stay, Item 19 or the electronic equivalent will include the date care began.

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Maternity Benefits

All expenses incurred for surgical and obstetrical care including preoperative/prenatal examinations, testing, and post-operative/postnatal services are part of the maternity package and billed under the appropriate surgical code on the date of delivery or termination. Charges the practitioner may impose that are not related to the delivery are incurred on the date furnished.

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Services Which Transpire to Another Calendar Date

This category could include multiple types of services. The service would be started on one day and concluded the following day. The service cannot be submitted to Medicare until completed. Unless otherwise notated, the billing entity can use either the date the service began or the following day when the service concluded.

Revised 2/27/2024