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Date of Service

Created: 11/15/13 | Updated: 02/26/2015
Question: What is the appropriate date of service to use when a diagnostic test has been interpreted?

There has been confusion on this topic due to CMS transmittal 1823 being rescinded. Transmittal 1823 was replaced by transmittal 1873. CMS anticipates clarifying DOS and POS rules in a future transmittal. Until further notice, UPI is following transmittal 1873 guidelines. Questions arose from a previous TOW sent out and we’d like to clarify:

Transmittal 1873 states “The appropriate DOS for the professional component is the actual calendar date that the interpretation was performed. For example, if the test or technical component was performed on April 30th and the interpretation was read on May 2nd, the actual calendar date or DOS for the performance (technical component) of the test is April 30th and the actual calendar date or DOS for the interpretation or read (professional component) of the test is May 2nd.” Also, you can find this frequently asked question and answer on the Novitas website:

6. What is the appropriate date of service to use when a test has been interpreted?

The interpretation must be billed with the date the physician actually provided the interpretation. The date of the professional component billed to Medicare Part B, and the date in both the supporting medical records and on the report must be in agreement. However, the date of the interpretation does not have to agree with the date of the technical component.

Date Posted: 08/08/2007, Date Revised: 11/15/2013

**NOTE: Special rules apply for the DOS on clinical laboratory and pathology specimens.