Place of Service (POS) and Date of Service (DOS) Instructions for Interpretation of Diagnostic Tests

As of July 1, 2010, Medicare contractors will consider, and providers must remember, that the appropriate DOS for the professional component is the actual calendar date that the interpretation was performed. 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 of the test is April 30th and the actual calendar date or DOS for the interpretation or read of the test is May 2nd.

NOTE: Special rules apply for the DOS of the technical component of clinical laboratory and pathology specimens and are contained in 42 CFR 414.510.

42 CFR – 414.510 Policy:

The DOS policy as specified in 42 CFR § 414.510 for either a clinical laboratory test or the technical component of physician pathology service is as follows:

1. General Rule: The DOS of the test/service must be the date the specimen was collected.
2. Variation: If a specimen is collected over a period that spans two calendar days, then the DOS must be the date the collection ended.
3. Exceptions: The following two exceptions apply to the DOS policy for either a clinical laboratory test or the technical component of physician pathology service:
   1. DOS for Tests/Services Performed on Stored Specimens: In the case of a test/service performed on a stored specimen, if a specimen was stored for less than or equal to 30 calendar days from the date it was collected, the DOS of the test/service must be the date the test/service was performed only if:
      • The test/service is 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 medically necessary for 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      • If the specimen was stored for more than 30 calendar days before testing, the specimen is considered to have been archived and the DOS of the test/service must be the date the specimen was obtained from storage.
   2. DOS for Chemotherapy Sensitivity Tests/Services Performed on Live Tissue:
   • In the case of a chemotherapy sensitivity test/service performed on live tissue, the DOS of the test/service must be the date the test/service was performed only if:
   • The decision regarding the specific chemotherapeutic agents 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.
   • For purposes of applying the above exception, a “chemotherapy sensitivity test” is defined as a test that requires a fresh tissue sample to test the sensitivity of tumor cells to various chemotherapeutic agents. CMS identifies such tests through program instructions issued to the Medicare contractors.