Four Rules to Report POS Correctly

Point of ServiceThe 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.

2017-code-book-bundles-728x90-01

Latest posts by admin aapc (see all)

5 Responses to “Four Rules to Report POS Correctly”

  1. Pete says:

    Does this mean that if a registered inpatient is seen in an outpatient wound clinic, we as coders are responsible for finding out that the patient is a registered inpatient and setting the POS code as 21?

    What about EHR systems that automatically append the POS?

  2. Maxine Lewis, CMM,CPC, CPC-I, CCS-P says:

    There was a question on the LIstserv a while back where a physician rendered care to an individual on the campus of a university. There is a POS for educational institution- is this appropriate. The consensus seemed to be office but I don’t think that is appropritate.

  3. Deb Kinkor, CPC says:

    Our physicians sometimes see patients at our office who are inpatients at a rehab hospital at the time of service. If we bill using POS 21, we’ll have to use hospital visit codes or the claims will be electronically rejected, and if we use POS 21 with our clinic as the location, our electronic system won’t even build a charge. We’ll also have to obtain an admit date and the attending physician’s name or, again, the claim won’t go through.

    So – For these patients, an otherwise 99213 OV should be billed as a 99232, POS 21, with the rehab hospital as the location?

  4. Dave says:

    We have hospitalists and some Psychologists who see patients in the ED as well as once they are in a room. Does anyone know what the policy would be for patients these doctors see that later become IP.

    In other words:

    01/01 – Psychologist does a consult on patient in the ER (ETOH w/ broken ankle maybe), the psychologist doesn’t actually admit the patient though, the patient is admitted by another doctor later that evening for say a broken ankle.

    Should the psychologist report a POS for the ED or should it be IP. Remember the patient was in the ED when the psychologist saw them.

  5. Rita says:

    Ok so if we have a patient that is recieving injections with a hosp bill type 731 but the provider states it was performed in office. Should both Pos be coded as an office visit? The provider is stating NO. That one can bill for the hospital and the other bill for an ASC visit

Leave a Reply

Your email address will not be published. Required fields are marked *