Health Information Management

Q&A: Correct billing for pre-admission services

JustCoding News: Inpatient, July 21, 2010

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Editor's note: Please note that the following Q&A was updated on October 6 to reflect the most recent CMS guidance.

QUESTION: I have a question related to packaging of pre-admission services (i.e., three-day rule). What date should I use when billing procedure code dates in FL 74 and FL 74 a–e?

The UB-Editor provides the following direction:

The procedure code dates must fall within the dates provided in the statement covers period (FL 6) except when an outpatient surgery procedure is reported on the inpatient claim. The date in this field may not be more than three days prior to the date of admission shown in FL 12.

Does this mean that if a service represented by any ICD-9-CM procedure code is performed prior to the admit date, I can report the procedure with a date of service prior to admit, but only three days prior to admit?

My thought is that this would happen only with nondiagnostic outpatient services.

Is my interpretation correct, and are there any sources with more definitive direction on billing of a date of service prior to admit date in FL 74?

ANSWER: Yes, CMS has instructed providers to bill outpatient procedures in the three days prior to admission, that are subject to billing on the inpatient claim under the three day payment window, with ICD-9 procedure codes and the date the procedure was provided. This is true even if this date is prior to the admit date reported in FL12. CMS notified providers that they tested CMS claims processing systems, and there are no edits currently in place that would prevent dates reported in FL 74 and 74a-e from being before the admit date.

Editor’s note: Kimberly Anderwood Hoy, Esq., CPC, answered this question. She is the director of Medicare and compliance for HCPro, Inc., in Marblehead, MA.

This answer was provided based on limited information submitted to Be sure to review all documentation specific to your own individual scenario before determining appropriate code assignment.

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