Place of Service for services without patient contact

[jonique.dietzen]

What is the correct place of service when the provider performs billable services without direct patient interaction? The Medicare guidelines state that the services should be billed with the location of the patient. But, when billed with POS 02 or POS 10, they are denying for invalid place of service. This is because these services are not allowed to be billed with the telehealth modifiers and are not on Medicare's telehealth services lists. POS 12 is also not a good fit because the provider is not present with the patient in their home and also can trigger a POS denial.

So what is the correct POS for these types of services? Supporting documents/legislation appreciated. (in the state of Oregon)

Examples:
99367-99368 Medical team conference with interdisciplinary team of health care professionals, patient and/or family not present
99374-99380 Care Plan Oversight: Patient Under Care of HHA, Hospice, or Nursing Facility
99492-99494 psychiatric collaborative care management
H0032 Mental health service plan development by nonphysician
T1007 Alcohol and/or substance abuse services, treatment plan development and/or modification