Medicare Helper: Don’t Let DOS Be the Downfall for Your Claims

select the correct DOS for claims

Determining date of service (DOS) can be harder than it seems. Once you dive into the world of professional/technical components, monitoring services, and other non-obvious DOS possibilities, things get complicated fast. You can use the Medicare rules below as a starting point.

Apply Different Dates for Radiology Components

For many radiology codes, the Medicare Physician Fee Schedule (MPFS) assigns a professional component and a technical component. That’s because it is not unusual for a patient to have an imaging service performed by a technician in one location and then for a radiologist who doesn’t bear the cost of that technical work to interpret and provide a report about the image. The reporting entities indicate the component they performed by using modifier TC (Technical component) or 26 (Professional component). If one entity is reporting both components (called the global service), that entity simply reports the code without TC or 26 appended. Here’s the DOS you should use, according to MLN Matters SE17023 (revised Feb. 1, 2019):

  • Global: “The provider can submit the professional component with a date of service reflecting when the review and interpretation is completed or can submit the date of service as the date the technical component was performed.” Using a single date may reduce the potential for claim issues.
  • Technical component: Use the date the patient received the service.
  • Professional component: Use the date the provider completes the review and interpretation.

Pick Up This Extra Tip for Pathology

You can follow the exact same bullet points that are above for reporting surgical and anatomical pathology codes with both professional and technical services.

The MLN Matters article adds that if the collection spans two calendar dates, you should use the date collection ended. For stored specimens, the MLN Matters article lists exceptions that you should review if you report these services.

Watch out: The MLN Matters article doesn’t cover every possibility. Pathology/Lab Coding Alert offers the example of evaluating three immunostains on a single date and a fourth immunostain on that same specimen as an addendum three days later. The advice is to ask your payer about how to report cases that don’t fit the general rule.

And That’s Not All …

The MLN Matters article covers quite a few other service types. Here are pointers on a few to show how different sorts of codes are handled, but be sure to review the complete article to see if any of the other services apply to you (specifically lab, ESRD, home PT/INR monitoring, psychiatric testing, surgical services including modifier 54 and 55, maternity benefits, and services that span dates).

  • Care plan oversight (CPO) requires 30 or more minutes of physician time per month. The DOS can be either the last date of the month or the date when that 30-minute time is completed.
  • For home health certification, the DOS is the date the physician completes and signs the plan of care. For recertification, use the date the physician completes the review.
  • Transitional care management (TCM) services are 30-day services, but the Medicare rule is to use the date of the required face-to-face visit as your DOS.
  • Cardiovascular monitoring services are often broken into separate codes, so each code may represent a distinct component. The different services may also apply to different time spans, like 24 hours or 30 days. If the code includes physician review, interpretation, and report (whether the code is professional or global), use the date the physician completes the work as the DOS. For the technical code, the date that monitoring concludes is the DOS.

What About You?

What do you do when Medicare guidance doesn’t cover the specific scenario you’re looking for? Are you able to get an answer in writing so you can keep that documentation in case you need to support your coding choices?


Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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