the journal of the healthcare billing and management association 45 evaluate when and if that exception can be utilized. What does all of this mean for providers in terms of Pos assignment and location designation on the claim form? the “special considerations” section revisions in the manual make it clear that cms is attempting to ensure that when a provider furnishes services to a “facility” patient (i.e., hospital inpatient, outpatient, etc.), they would require the claim to reflect that designation “irrespective of the setting where the patient actually receives the face-to-face encounter.” the oig findings have seemingly left cms to move to ensure the correct facility Pos is denoted when services are provided in a different setting to avert any incorrect site of service differential paid. for example, when a hospital inpatient goes to a physician’s office for evaluation during their hospital stay, the office services billed by the physician during that time period will use the inpatient hospital Pos code when submitted. this may not be a large change for many physicians who perform mainly face-to-face encounters and don’t routinely see facility patients in another setting besides the facility, but for those who perform remote interpretations, the new Pos instructions and clarified service location requirements have been daunting if not enacted already. for those providing remote diagnostic interpretive services, industry recommendations have included that they state an interpretive location in their medical record documentation through dictation or electronic means; to work with vendors to establish an electronic solution if possible; and, most importantly, to commence on any necessary enrollment activities. the remote interpretation locations may need to be enrolled as additional service locations with medicare, and if the interpretive service is provided within another separate carrier jurisdiction from where the technical service was provided, there are likely additional enrollment actions to be had. some of the struggles mentioned above have included the inclusion of the interpretive location on the medical record; for those who provide remote interpretive services, it has been challenging to find an efficient and effective way to include it. additionally, the software vendors and platforms are working to find solutions to ease the burden and to also allow for the maintenance of the various locations (i.e., the tc and the Pc location) for internal reporting purposes. the best practice in these situations is to have both the technical and interpretive location always identified in some way on the medical record in order to work through the claim submission requirements. the guidance has been forthcoming for quite a while, and it does not appear that cms will delay, revise, or rescind the instructions again (although it would be wise to “never say never”). the pathology specific clarifications are yet to be published and should be expected in the very near future – by the time this article is released, they should have been published by cms. these instructions for some providers, especially those who provide remote diagnostic interpretations, have left them feeling that they are working through a maze of new issues that may not have been encountered before. if you have neither reviewed nor started towards compliance with the new clarifications, it is better late than never to forge ahead. Missy T. Lovell, BSN, MBA, serves as the corporate compliance manager for Medical Management Professionals, Inc. (MMP). Ms. Lovell has spent her entire career in the healthcare industry, beginning as a registered nurse caring for pre- and post-operative surgical patients. She graduated from the University of Tennessee in Knoxville and went on to work in various clinical training and administrative positions for the same not-for-profit health system. In 1991, Ms. Lovell began working with the Physician Management Services Department and was the regional practice administrator for many medical practices within the health system. She began her career with MMP in March 2000. HBMA EVENTS CHBME Executive Development Summit with Visit the Hill Day july 17-20 the Washington court hotel on capitol hill Washington, dc HBMA National Conferences FALL 2013 september 18-20, 2013 caesars Palace • las Vegas, nV Owners & Managers FALL CONFERENCE october 24-26, 2013 millennium Knickerbocker hotel • chicago, il
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