CMS Issues New Place-of-Service Code (POS) Instructions

February 16, 2012 – On February 3, 2012, CMS issued a new transmittal (CR7631) updating their instructions for reporting the place of service (POS) when billing claims to Medicare for services paid under the Medicare Physician Fee Schedule (MPFS).
 
The new transmittal establishes that for all services paid under the MPFS, with two exceptions, that the POS code to be used by the provider will be assigned as the:

• same setting in which the benefiticary received the face-to-face service, or
• in cases where there is not face-to-face service, as as when a provider provides the professional component of diagnostic testing, laboratory or other services; thePOScode will be the setting in which the beneficiary received the technical component (TC) of the service.

There are 2 Exceptions to this face-to-face provision/rule in which the physicians always uses the POS code where the beneficiary is receiving care as a inpatient (code 21) or an outpatient (code 22) of a hospital, regardless of where the beneficiary encounters face-to-face service.
   
Mobile Unit Settings
 
If the mobile unit is serving an entity for which another POS code already exists, the providers should use the POS code for that entity.  Ex.  If the mobile unit is sent to a Skilled Nursing Facility (SNF) to perform services for the SNF’s patients, the SNF should be the POS.
 
However, if the mobile unit is not serving an entity which could be described by an existing POS, the providers are to use the Mobile Unit POS code 15.
 
Physicians With a Private Office Within a Hospital
 
Providers who perform services in a hospital outpatient department will use POS code 22 unless the physician maintains separate office space in the hospital or on the hospital’s campus and as long as the  physician office space is not considered a provider-based department of the hospital as defined in 42. C.F.R. 413.65.  In this case, the physician may use POS 11 (office). The physician is subject to the physician self-referral provisions set forth in 42 C.F.R 411.353-411.357.
 
Ambulatory Surgical Centers
 
When a provider performs services in a Medicare-participating ASC, the provider will use the ASC POS of code 24.  Providers may not use POS code 11(office) for ASC based services unless the physician has an office at the same physical location of the ASC which meets all requirements for operating as a physician office at the same physical location as the ASC.
 
Qualifications for an office setting at an ASC can be found in Appendix L by clicking below:
 
ASC Manual
 
Hospice & Walk-in Retail Health Clinics – See the following link for more information.

More information along with examples of place of service scenarios can be found by clicking below on the MLN Matters article.
 
MM7631

Tags: CMS Updates