The Medicare Place of Service Workgroup recently revised the telehealth place of service codes to reflect the need for greater specificity in the industry.
Telehealth POS Code Changes
POS 02 has been changed to reflect patients who receive telehealth in locations other than their home, and POS 10 has been added to reflect patients who receive telehealth in their home. The following are the new descriptions for each code:
- POS 02: Telehealth Provided Other than in Patient’s Home – The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
- POS 10: Telehealth Provided in Patient’s Home – The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
These changes are effective January 1, 2022. However, consult each payer’s billing guidelines before using the new POS code 10 or adapting the definition of POS code 02.
For instance, Medicare itself has not identified a use for the new POS code 10 within their own billing guidelines, according to MLN Matters Number: MM12427. Rather, they created the new POS code because “the healthcare industry has a greater need for specificity than Medicare,” and “this eases coordination of benefits and gives other payers the setting information they need.”
Telehealth POS Codes for Medicare
So how do you indicate POS when billing telehealth to Medicare?
For dates of service March 1, 2020, through the end of the COVID-19 Public Health Emergency (PHE), the following guidelines have been established for indicating place of service when billing telehealth to Medicare:
- Place of Service (POS) equal to what it would have been had the service been provided in-person
- Modifier 95, indicating that you provided the service via telehealth
Prior to the COVID-19 PHE, the patient’s place of service was indicated with code 02, which previously indicated all telehealth patient sites. Unless telehealth requirements are changed, following the COVID-19 PHE patients will once again be restricted to the following originating sites, which would all continue to be covered under the new description of POS code 2:
- The office of a physician or practitioner;
- A hospital (inpatient or outpatient);
- A critical access hospital (CAH);
- A rural health clinic (RHC);
- A federally qualified health center (FQHC);
- A hospital-based or critical access hospital-based renal dialysis center (including
- A skilled nursing facility (SNF); and
- A community mental health center (CMHC)
For more information about the updates to the telehealth POS codes, along with POS guidelines for billing Medicare, check out the following resources:
- MLN Matters Number: MM12427 – New/Modifications to the Place of Service (POS) Codes for Telehealth
- Medicare Payment for Telehealth Services Section in the Medicare Claims Processing Manual (begins on page 139)
- Billing for Professional Telehealth Distant Site Services During the PHE Section in the MLN Matters Number: SE20011 – Medicare FFS Response to the PHE on COVID-19 (begins on page 9)
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