FOLLOW UP: A Clarification About Medicare Place of Service Codes

(Yes, I Sometimes Get it Wrong)

By Barbara Griswold, LMFT (March 26, 2025)

If mistakes are proof that you are trying, I must really be trying!

In last week’s Medicare update article, I focused on the postponement of the in-person visit requirement for telehealth clients until September (if you missed that article, click here).

However, in the paragraph on Medicare coding I made some statements about the Medicare Place of Service codes for telehealth that need some clarification.

I stated that POS 10 should be used when the client is at home, and POS 02 when the client is elsewhere.  Two astute readers wrote to point out that this was not quite right.

HERE’S WHAT I SHOULD HAVE SAID ABOUT MEDICARE CODING:

There has been confusion about the use of Place of Service Codes for Medicare claims.  The official POS Code set and many Medicare websites say that POS 10 is to be used for telehealth when the client is at home, and 02 when the client is not located in their home.

But a deeper reading of CMS documents indicates that POS 10 may be used when the client is at ANY non-facility location.  The NGS Medicare website even states “CMS has clearly indicated that POS 10 is used when the patient is not in a hospital or other facility where a patient receives care. 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.”

So, it seems Medicare intends us to use POS 10 for everything other than when your client is at a facility.

Why does this matter? Because if you use the POS code 02, you can expect to be paid at the lower “facility rate.” 

Some reminders:

• It’s wise to check with your regional Medicare Administrative Contractor (MAC) to verify billing codes.
• This guidance does not apply to private health plans, that would typically expect 02 to be used when the client is located anywhere other than at their home.
•  In-person sessions at your office should be coded as POS 11 for Medicare, with no modifier.
• Always be sure to document where the client is located in your session note, and whether the session was video or audio.  I’d even document the CPT code and any modifier in each note.

And a clarification about modifiers: I also wrote that with Medicare, private practices should be sure to use modifier 93 for phone sessions, and 95 for video sessions for Medicare sessions.  Several people wrote to ask if this was a change from 2024, when we were told to leave off modifiers from telehealth claims, or that they were not required, but were “information only”  Yes, there has been some conflicting guidance in previous years about the inclusion of modifiers.

Several people wrote to tell me that they are getting paid without modifiers on their claims. Says Medicare Expert Susan Frager of PsychBillingCoach.com, this is also true. “Since last year, Medicare will pay for video sessions with or without the 95 modifier, but for phone sessions you must use 93 (see citation here).” When in doubt, I’d include modifiers – I hate to give Medicare any ammunition to deny a claim.

One other point I didn’t mention in my article: Medicare providers can continue to provide telehealth services to clients anywhere in the country, as long as they are licensed or have permission to practice in the state in which the patient is located at the time of service, at least until September 30, 2025.