Telehealth – Updates to the Place of Service Codes The place of service (POS) code set provides location information necessary to pay claims correctly. There are times when the health care industry requires a greater need for specificity than Medicare. While Medicare may not require this greater specificity to process and pay claims, it will adjudicate claims with the new codes in order to provide coordination of benefits and give other payers the location information they need to appropriately process and pay claims.

Updated POS Codes: 

The POS Workgroup has revised the description of POS code 02 and created a new POS code 10 to meet health care industry needs. Effective for dates of service January 1st, 2022, the following revisions are as follows: 

  • POS 02: Telehealth Provided Other than in Patient’s Home
    • Descriptor: 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
    •  Descriptor: 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.

Special Considerations for Telehealth Claims: 

While the modification of POS Code 02 and the creation of POS Code 10 are effective in the National POS code set effective January 1st, 2022, Medicare contractors received instructions from CMS indicating claims with these codes can be processed starting April 4, 2022, so that Medicare would align with existing Telehealth claims processing policy, as well as be considered HIPAA compliant. 

Claims can still be submitted to Medicare contractors with POS 10 for dates of services effective January 1st, 2022, but the Medicare contractors may hold those claims for processing until April 4, 2022. 

Additionally, your practice should consult each payer’s billing guidelines before using the new POS code 10 or adapting the definition of POS code 02. For instance, Anthem and United Healthcare (UHC) now require both commercial and Medicare Advantage plans to use the new POS code 10 for telehealth RT Welter & Associates, Inc. pg. 2 Eff. 3/2/2022 services provided in the patient’s home. POS code 02 should continue to be used for telehealth provided anywhere other than a patient’s home (e.g., hospital or SNF). 

Traditional Medicare hasn’t identified a need for the new POS code 10. The Medicare contractors will instruct providers to continue to use the Medicare billing instructions for Telehealth claims in Pub. 100- 04, Medicare Claims Processing Manual, Chapter 12, Section 190.

How the COVID-19 Public Health Emergency Effects this Update 

During the COVID-19 Public Health Emergency (PHE) traditional Medicare will continue to require physicians to bill as follows:

  • 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. (e.g., Office POS 11)
    • 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. After the COVID-19 PHE, unless there’s a legislative change, CMS and the submission of traditional Medicare only claims, will revert to the geographic/originating site requirements for most telehealth services which would be covered under the new description of POS cod 2 and include the locations listed below.

  • 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 • satellites);
  • A skilled nursing facility (SNF); and 
  • A community mental health center (CMHC)