Has there been a change in the DOS to be used for TCM codes?
According to a section from the 2016 Final Rule, they will allow us to use the face-to-face DOS as the reported TCM DOS on the claim.
"...Regarding TCM services, we are adopting the commenters’ suggestions
that the required date of service reported on the claim be the date of the
face-to-face visit, and to allow (but not require) submission of the claim when
the face-to-face visit is completed, consistent with current policy governing
the reporting of global surgery and other bundles of services under the PFS. We
will revise the existing sub-regulatory guidance for TCM services accordingly..."
It did not seem appropriate to me, without a need to update the 30 -day service period description included in the definition of the code, however, it will certainly ease up the administrative burden in holding these claims for a 30 day period prior to releasing for payment!