Note Medicare’s New Place-of-Service Policy

Medicare’s policy for the assignment of place-of-service (POS) codes will change April 1, 2013 (This is a delay from the original Oct. 1, 2012, effective date.)

The old (and still current) policy instructs physicians to use the two-digit POS code to describe where they were physically when rendering the service; in this instance, the POS code corresponded to the service location.

The new policy, establishes that for all services — with two exceptions — physicians will use the POS code assigned to the setting in which the beneficiary has received the face-to-face service. Because a face-to-face encounter with a physician is required for nearly all Medicare services, this rule clearly will apply most of the time.

In cases where the face-to-face requirement is obviated, such as those when a physician provides the professional component (PC)/interpretation of a diagnostic test from a distant site, the physician will assign a POS code for the setting in which the beneficiary received the technical component (TC) of the service.

For example: A beneficiary receives an MRI at an outpatient hospital near 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 office location. The physician would use POS code 22 on his claim for the PC to indicate that the beneficiary received the face-to-face portion of the MRI, the TC, at the outpatient hospital.

The two exceptions: The physician should always uses the POS code where the beneficiary is receiving care as a hospital inpatient (POS code 21) or an outpatient of a hospital (POS code 22) regardless of where the beneficiary encounters the face-to-face service. The Medicare Claims Processing Manual already requires this for physician services (and for certain independent laboratory services) provided to beneficiaries in the inpatient hospital; the new policy clarifies this exception and extends it to beneficiaries of the outpatient hospital, as well.

For more information, seeCenters for Medicare and Medicaid Services Transmittal 2561 (PDF). This notice includes special notes for the following POS codes: Mobile unit settings (Code 15), walk-in retail health clinic (code 17), inpatient hospital (code 21), outpatient hospital (code 22), ambulatory surgical centers (code 24), and hospice (code 34). Also included are lists of settings paid at the facility and nonfacility rate.

Don’t miss TMA’s Medicare 2013 seminar to find out what’s new with Medicare payment and policies for the coming year. The seminar runs Oct. 30- Nov. 15 in various locations around the state.  Register now.

Published Sept. 27, 2012 


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