Lately, it feels like every week there is a new procedure code, but do you pay attention to new place of service codes? Most are familiar with Place of Service 02, but there was a description update. Place of Service 02 is now called Telehealth Provided Other than in Patient’s Home with description of:

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.  (Effective January 1, 2017, Description change effective January 1, 2022, and applicable for Medicare April 1, 2022.)1

The newest Place of Service code to enter the arena is Place of Service 10 which is labelled Telehealth Provided in Patient’s Home. The full description is as follows:

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. (This code is effective January 1, 2022, and available to Medicare April 1, 2022.)2

The main difference between the two codes is the location of the patient. Place of Service 02 the patient is NOT at home while Place of Service 10 should only be used for when patients ARE at home.   While the changes became effective January 1, 2022, they do not apply to Medicare until April 1, 2022.

According to CMS Transmittal 110453 that while the modification of POS Code 02 and the creation of POS Code 10 are effective in the National POS code set effective January 1, 2022, Medicare contractors received instructions regarding how to process claims with these codes starting April 4, 2022, so that Medicare would align with existing Telehealth claims processing policy, as well as be considered HIPAA compliant.

What to look for?

  • Check other claims billed for the member that day, what was the POS listed on that claim? Was it possible to bill either POS 02 or 10 for that patient?
  • What services were rendered? Are these services eligible for telehealth reimbursement?
  • Is the provider eligible to deliver telehealth services?
  • If documentation for the visit is provided, does it meet the same requirements as an in person visit?
  • Is the correct POS being used? Services provided in the patient’s home should not be billed with POS 02 per the new code changes. Check with your payors policy for the implementation date.

Don’t forget to append any applicable modifiers to your telehealth services!

References:

https://www.cms.gov/Medicare/Coding/place-of-service-codes/Place_of_Service_Code_Set

https://www.cms.gov/files/document/mm12427-newmodifications-place-service-pos-codes-telehealth.pdf

https://www.cms.gov/files/document/R11045CP.pdf