POS Coding Must Match Setting Where Service Was Provided
When assigning a place-of-service (POS) code for your Medicare claims, be sure that the POS matches the setting in which the patient received the service (for face-to-face services), or the setting in which the technical portion of the service was delivered (for non face-to-face services, such as interpretation of diagnostic test results).
There are two exceptions to the rule:
1. When a physician/practitioner/supplier provides services to a patient who is an inpatient of a hospital, the inpatient hospital POS code 21 will be used regardless of the setting where the patient actually receives the face-to-face encounter.
2. Physicians/practitioners who perform services in a hospital outpatient department will use POS code 22 (Outpatient Hospital) unless the physician maintains separate office space in the hospital or on hospital campus and that physician office space is not considered a provider-based department of the hospital as defined in 42. C.F.R. 413.65. Physicians will use POS code 11 (office) when services are performed in a separately maintained physician office space in the hospital or on a hospital campus and that physician office space is not considered a provider-based department of the hospital as defined in 42.C.F.R. 413.6. Use of POS code 11 (office) in the hospital outpatient department or on hospital campus is subject to the physician self-referral provisions set forth in 42 C.F.R 411.353 through 411.357.
The above guidelines were recently clarified by Centers for Medicare and Medicaid Services (CMS) CR Transmittal # R2407CP (https://www.cms.gov/transmittals/downloads/R2407CP.pdf), and MLN Matters® Number: MM7631 (http://www.cms.gov/MLNMattersArticles/Downloads/MM7631.pdf), the latter of which provides the following example:
“A beneficiary receives an MRI at an outpatient hospital near his/her home. The hospital submits a claim that would correspond to the TC portion of the MRI. The physician furnishes the PC portion of the beneficiary’s MRI from his/her office location—POS code 22 [outpatient hospital] will be used on the physician’s claim for the PC to indicate that the beneficiary received the face-to-face portion of the MRI, the TC, at the outpatient hospital.”