CMS Delays Place of Service (POS) Transmittal 2407 Until October, 2012

In a showing of support to physicians, particularly pathologists and radiologists who do not have "face to face" patient encounters, the Centers for Medicare & Medicaid Service (CMS) announced on March 30, 2012 that it will delay implementation of its revised Place of Service (POS) coding instructions from the intended "go live" date of April 1, 2012 to a new implementation date of October 1, 2012.  The delay of implementing Transmittal 2407 will be published in Transmitted 2435, which will be posted on CMS' website in the coming days.  Once posted, it can be viewed here (at press time, the CMS website was experiencing technical difficulties, and although the Transmittal details are posted, the Transmittal itself is not available.  PIMS will update this information on this website once available).

This delay can be directly tied to recent pressure from physician advocacy groups, who brought concerns over the confusion and unintended consequences which would result from this Transmittal to agency officials and lawmakers.  The Medical Group Management Association (MGMA) addressed Administrator Tavenner in a letter on March 21, 2012, requesting CMS take additional time to evaluate the effect the policy would have on physician group practices.  The College of American Pathologists (CAP) addressed similar concerns with lawmakers on Capitol Hill, resulting in letters from Iowa and Alabama Congressmen to CMS Acting Administrator Marilyn Tavenner on March 29 requesting a delay.  Both CAP and MGMA deserve accolades for bringing this to CMS's attention, and physician providers and laboratories are fortunate to have such active organizations working tirelessly to ensure the government is aware of how its policies may negatively impact them.

This delay also provides some relief to providers who will be affected by the expiration of the TC Grandfather Clause (scheduled to sunset on June 30, 2012).  The intended April 1, 2012 implementation date for the POS change was causing much concern over anatomic pathology services, particularly for providers whose claims were processed under this Grandfather Clause.  The timeframe between April 1, 2012 and July 1, 2012 was causing heartache for laboratories processing these claims, as well as the hospitals and other part B contractors whose patients such laboratories service; no one was sure which places of service would be appropriate during that timeframe and processed accordingly.  This type of unintended negative consequence will now hopefully be avoided due to CMS's delay. 

Thank you to CAP and MGMA for their hard work, and thank you to CMS for their cooperation in avoiding a potential disastrous situation.  PIMS will continue to work with outside counsel and outside agencies representing physicians' interests to ensure the final POS policy is appropriate, accurate, and does not cause unintended consequences.  Please contact us with any suggestions you may have, as well as with any questions which may result from this CMS delay.

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