Four Rules to Report POS Correctly
The Centers for Medicare & Medicaid Services (CMS) has updated its policy on place of service (POS) coding. The revisions are more about “housekeeping” than substantive change, but with the Office of Inspector General (OIG) continuing to target POS assignments as a problem area, there’s no time like the present to perfect your POS coding.
Medicare POS guidelines are set forth in the Medicare Carriers Manual, Chapter 12, section 20.4.2, and boil down to four basic rules:
1. Services rendered to a patient who is a registered inpatient should be reported with POS code 21 (or other appropriate inpatient code), regardless of where the services were provided. If you know the exact setting in which the patient is a registered inpatient, you may report another appropriate inpatient POS code (rather than POS 21). For example, you may use POS 31 for a patient in a skilled nursing facility (SNF) receiving inpatient skilled nursing care or POS 51 for a patient registered in a psychiatric inpatient facility, etc.
2. Service rendered to a patient who is a registered outpatient should be reported with POS code 22 (or other appropriate outpatient code), regardless of where the services were provided. If you know the precise setting in which the patient is a registered outpatient, you may report another appropriate outpatient POS code (instead of POS 22). For example, report POS 23 for services furnished to a patient registered in the emergency room, POS 24 for patients registered in an ambulatory surgical center (ASC), etc.
In other words: If a patient is a registered inpatient or outpatient, a facility POS is appropriate, no matter where the encounter actually occurs.
3. When face-to-face services are provided for a patient who is not a registered inpatient or outpatient, the POS code should match the setting in which the beneficiary received the face-to-face service.
4. When there is no face-to-face service (e.g., the physician provides interpretation of a diagnostic test, only), the POS is that in which the beneficiary received the technical component (TC) of the service.
CMS example: The patient receives an MRI at an outpatient hospital near his/her home. The hospital submits a claim for the TC portion of the MRI. A physician performs the professional portion of the beneficiary’s MRI (i.e., the interpretation) in his office. In this case, the POS for the physician service is the outpatient hospital (POS 22)—even though the interpretation occurred in the physician office—because that is where the patient received the face-to-face portion of the MRI.
CMS requires special considerations for services provided in mobile units (POS 15), walk-in retail health clinics (POS 17), and hospice (POS 34). See CMS Transmittal 2613 for complete information.