Medicare POS Codes for Telehealth: What’s the Latest???
By Barbara Griswold, LMFT (May 11,2022)
As if telehealth billing isn’t confusing enough, Medicare providers are having a hard time getting answers about what Place of Service (POS) code to use for these sessions. Conflicting advice is coming from all sectors. And while I’m not a Medicare expert, I received so many questions about this issue, I was curious to get to the bottom of it.
Pre-pandemic, most of us billed using POS code 11, to let the health plan know we provided the service in our office. Fast forward to March 2020, and we’re all doing telehealth. Private health plans instructed us to use the telehealth POS code 02 for these sessions. But Medicare told us that for their members we should continue to use the 11 POS code — even for telehealth.
Then, effective January 1, 2022, POS code 10 was introduced for telehealth sessions when the client was at home. POS code 02 was now to be used for telehealth when the client was anywhere else. Medicare once again did NOT follow suit, stating that they would not be using these codes until April 2022.
So here we are in May. If you billed Medicare in April using the 10 or 02 codes, you were likely unpleasantly surprised to find that while your claims processed, they were paid at a reduced rate. Why? For the same reason Medicare has wanted us to stick to using POS code 11: Because their computers are set up to reimburse telehealth POS codes at a lower rate.
So — what POS code should you be using for Medicare clients NOW? It turns out Medicare seems to be instructing providers to continue to use the POS code 11 for telehealth sessions — at least until the end of the federal Public Health Emergency (PHE).
And when will the Public Health Emergency end? Hard to know. It can only be renewed for 90 days at a time — it was just renewed April 16, 2022. President Biden has made it clear he wants it to be extended to the end of 2022, but he doesn’t have complete control of this.
When it comes to what POS code you should use now for Medicare, you might have been told something else. So let me present my sources so you can make your own decisions:
1. The Medicare website (updated April 22, 2022): “When billing telehealth claims for services delivered on or after January 1, 2022, and for the duration of the COVID-19 emergency declaration. Include Place of Service (POS) equal to what it would have been had the service been furnished in person….Append modifier 95 to indicate the service took place via telehealth.” (Read the rest of the information– click here)
2. NGS Medicare’s website on the use of POS code 10 (rev. 3/16/22) click here
- Medicare’s own COVID 19 FAQs (see Page 75) directs telehealth providers “to report the place of service (POS) code that would have been reported had the service been furnished in person. This will allow our systems to make appropriate payment for services furnished via Medicare telehealth which, if not for the PHE for the COVID-19 pandemic, would have been furnished in person, at the same rate they would have been paid if the services were furnished in person….” (Read the rest of the information on Page 75 — click here)
- The American Psychological Association in a recent article states “in Medicare, telehealth providers have been instructed to use POS 11 along with modifier 95 during the [Public Health Emergency] PHE. This is to insure that during the PHE providers are reimbursed at the higher non-facility rate.” While they note that the POS codes 10 (client at home) and POS code 02 (client elsewhere) are now available for use, they state “Medicare has communicated that Change Request 12427 is not requiring Medicare providers to change anything on how they are currently billing their telehealth claims during the PHE.” (Read their entire article here)
- Medicare Pub 100-04 Medicare Claims Processing: “During the [Public Health Emergency] PHE, Medicare does not require the use of telehealth Place of Service codes. Any change of policy regarding use of telehealth POS codes following the end of the PHE would be addressed in subsequent instruction. Medicare contractors are to instruct their providers to continue to bill according to current applicable rules. However, Medicare contractors are to adjudicate claims containing this new code should it appear on a claim the same way they would adjudicate claims with POS 02.” –(read the rest of this publication — click here )