CMS Postpones POS Rule to October

Wondering why the place of service (POS) coding rules is not yet in place? Here’s why.

The Medicare Transmittal 2407, which focuses on place of service (POS) coding rules, was earlier set to be effective April 1, 2012, with an implementation date of April 2, but now CMS announced that the new effective and implementation dates have been set as Oct. 1, 2012. To review the rules and the announcement, you’ll need to check Transmittal 2435, which replaced Transmittal 2407.

The new Transmittal: "Transmittal 2407, dated February 3, 2012, is being rescinded and replaced by Transmittal 2435 to change the effective date from April 1, 2012, to October 1, 2012, and to change the implementation date from April 2, 2012, to October 1, 2012. This delay will allow CMS to address questions received and to make any necessary changes. All other information remains the same."

Until the new rule becomes effective, continue to follow your payer’s current guidance on choosing the POS code.

"Despite the implementation delay, you should review your POS coding policies" in light of the transmittal instructions to ensure that you’re ready when CMS announces the final effective date, says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. and publisher of the Pathology Service Coding Handbook, in The Villages, Fla.

Resources: You may review Transmittal 2435 and its accompanying MLN Matters article at the following addresses:

www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads//R2435CP.pdf

www.cms.hhs.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM7631.pdf