Telehealth POS

[ashtonmr32]

Hello all,

I have been having a hard time finding a consistent answer for when to post POS 2 vs POS 10 for telehealth. I am seeing mixed responses where, POS 2 should only be used if the patient is outside of their home when being seen and POS 10 should be used when the patient is home. I'm also seeing POS 2 should be used if the provider is at a facility or office and the patient is home outside rural areas and POS 10 is used when a patient is in rural areas. I'm also finding POS 10 is only used for medicare. Is anyone able to clarify for me which is correct? I work in a pediatric therapy clinic and we have been using POS 2 but have had questions on if this is the correct POS to use. TIA.

 

[csperoni]

The POS guidelines for telehealth could vary by payor.
For Medicare, POS 10 is for patient at home (which would include places like their work, or a friend's house, a car, etc. Basically, NOT a facility/medical office). POS 02 is for patient is not at home (meaning a hospital or other place they receive medical care).
My MAC (NGS) came out with this fact sheet stating:
"If the patient receives the telehealth service from a location that is not a facility they would normally receive care, such as their car or work, then POS 10 would be appropriate based on this description provided by CMS in the final rule."
In my opinion, their descriptions of 02 & 10 are very misleading. I believe the intent is 02 is when a patient is in a facility where they would receive healthcare. 10 would be when a patient is located other than a hospital/facility where they would receive care (with home simply being an example). The problem is that CMS defines home as "a location other than a hospital or other facility where the patient receives care in a private residence." All other English speaking people would define their home as "where I live/reside."

For commercial plans, you have to follow whatever their guidelines/policies are.

 

[jkyles]

The issue of rural vs non-rural is based on "normal" telehealth rules. That is, without the various temporary waivers telehealth is restricted to patients who live in a rural area with some exceptions. Under "normal" telehealth, most patients must go to an originating site such as a hospital, physician's office etc for telehealth. In that case the service would continue to be reported with POS 02. There are some exceptions that allow all Medicare patients to receive telehealth from home regardless of their geographic location. Those telehealth services would be reported with the newer POS 10.

The temporary exceptions don't impact the place of service rules, you're still looking at where the patient was, but more services can be reported with POS 10.

I'll add that I've received questions about how to bill when the patient comes to the practice, the treating provider is not at the practice for some reason (typically they're WFH because they have a fever or other symptoms) and a telehealth visit is performed. I understand people aren't happy about the pay reduction but obviously the physician's office isn't the patient's home.