Anesthesiologists now have some flexibility when choosing which date to bill Medicare for services that continue into a second calendar day.
According to MLN Matters Number: SE17023, released in late January 2019, for services which transpire over to another calendar date, “Unless otherwise notated, the billing entity can use either the date the service began or the following day when the service concluded.”
While anesthesia services are not specifically mentioned as an example, the Centers for Medicare and Medicaid Services (CMS) does say this category includes “multiple types of services” and doesn’t specifically exclude anesthesia services or suggest choosing a DOS for them using an alternate method. The only condition for the DOS flexibility in these cases is that the service cannot be submitted to Medicare until it is complete.
In an earlier version of MLN Matters Number: SE17023 released on September 19, 2017, CMS indicated that services that span two days should be billed using the latter date, or the date the service ended, and in that directive, did specifically list anesthesia services as an example. However, that version of the article was rescinded just days later on October 2, 2017. The new version published January 24, 2019, no longer contains the restriction to use the second day or the particular anesthesia example.
For more information on CMS’s Guidance on Coding and Billing Date of Service on Professional Claims, review MLN Matters Number: SE17023.
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