Did You Hear? New 2022 Place of Service Billing Codes

By Barbara Griswold, LMFT

(Jan. 25, 2022, updated in parts May 10, 2022, updates in red)

[Note: Whether you work with insurance or not, this applies to you!]

 

Were you just getting the hang of telehealth billing codes? Well, the folks at the CMS (Center for Medicare and Medicaid Services) just decided to make things more complicated by changing the telehealth Place of Service codes — for all health plans.

“What is a Place of Service (POS) Code?” This is the two-digit code used on claims (Box 24B) to tell where the session took place (for the complete list of POS codes, click here).  Historically therapists have primarily done office sessions, so used only one code — POS 11.

“But I’ve never put a POS code on my superbills.”  Right, many out-of-network therapists have never included the POS code on a superbill/invoice, but it’s a good idea.  Health plans assume if there is no POS code, the session was in the office, and coverage may be different for office and telehealth sessions.

“So, what is changing?”  Effective Jan 1, 2022, the CMS changed the definition of POS code 02 we’ve been using for telehealth, and introduced a second telehealth POS code 10:

• POS 10: Telehealth to a client located at home (does not apply to clients in a hospital, nursing home or assisted living facility)
• POS 02: Telehealth to a client who is not located at home

“So, should I start using these new codes?” Wait! Don’t go rushing off to start using the new codes immediately  It seems some health plans are ready to accept the new POS codes and others are not.  Some have informed providers of the new codes but haven’t clearly given the green light to use them yet.  Here is a partial list of plans and what they are saying to providers about the new codes:

Aetna:  Doesn’t appear to be accepting the new code or at least they haven’t updated their telemedicine billing FAQ online — click here.  However, one provider reached out and said her claims using the POS 10 code were paid by Aetna.

Beacon:Can’t find any new info regarding the new code on their website.  However, one provider stated “I have billed for sessions in January with Beacon with POS 10 and included the 95 modifier and had the bills accepted and paid.”

Blue Cross and/or Blue Shield Plans:

• • Alaska (Premera BCBS),
  • California (Anthem Blue Cross of CA) — Update: While some providers reported January claims using POS 10 were pended/held up for payment, as of mid-February providers have reported these have been paid.  
  • Carefirst (Maryland, Washington, D.C. and Northern Virginia) –unsure — no information could be found
  • Colorado
  • Connecticut
  • Florida
  • Georgia
  • Idaho (Regence BS of Idaho): 4/10/22: Website states. “Claims for eligible telehealth services must be billed with POS 02 or POS 10, as appropriate, and modifier GT. Telehealth services may be conducted via audio or video. Claims for audio-only telehealth services must have modifier FQ appended, in addition to modifier GT.”
  •   Click here for more info.
  • Indiana
  • Iowa — One provider had her POS 10 claims denied.  Blue Cross later stated that “the system edit causing the denials will be updated on January 25, 2022 to allow POS 10…It is acceptable to bill POS 02 on new claims up to February 1, 2022.  Wellmark will initiate a claims remediation project request to reprocess impacted claims once the system has been updated on January 25, 2022.  It could be several weeks or more.  If you do not wish to wait for the claims remediation project to be completed, you may begin submitting provider inquiries through the Check a Claim tool online at Wellmark.com after the system has been updated on January 25, 2022 and request that the claims be reprocessed.
  • Kentucky
  • Maine
  • Massachusetts: On the website, they say they will accept POS codes 02 or 10 for telehealth.  For info, click here; While one provider was told to keep using 02 until 4/1, this confusion may have occurred  because their Medicare plans are not switching over until then
  • Michigan: Started accepting POS code 10 on 2/1 for sessions starting 1/1/22
  • Missouri
  • Nevada
  • New Hampshire
  • New York (Empire BCBS)
  • Ohio
  • Oregon (Regence BC/BS) — Confirms they accept POS 10 and reminds you they require modifier GT, and will reject 95 modifier.  For phone sessions, add a FQ modifier to the GT
  • Texas BCBS: One provider reported on 1/25: “I submitted all of my claims on Availity for BCBS of Texas using POS 10 for January, and were sent back with a message saying “resubmit with POS 2.”  I resubmitted and they were paid.”
  • Utah (Regence BCBS of Utah) — Confirms they accept POS 10 and reminds you they require modifier GT, and will reject 95 modifier. For phone sessions, add a FQ modifier to the GT
  • Washington:
    • Premera BCBS or
    • Regence Blue Shield — 4/10/22 website: 4/10/22: Website states. “Claims for eligible telehealth services must be billed with POS 02 or POS 10, as appropriate, and modifier GT. Telehealth services may be conducted via audio or video. Claims for audio-only telehealth services must have modifier FQ appended, in addition to modifier GT. Washington providers: An established provider-patient relationship is required for audio-only services. Member consent must be obtained and documented in the medical record prior to a virtual service performed using audio-only technology.”
  • Wisconsin

CIGNA/Evernorth: On January 7th, 2022, CIGNA / Evernorth sent a confusing email to many providers, letting them know about the new codes.  It stated that Medicare would not be using the POS code 10 until April, 2022, and that “in the interim, Cigna commercial [i.e. non-federal or state plans] still asks providers to bill with a typical face-to-face place of service (e.g., POS 11), and to not bill POS 10 until further notice.”  This surprised providers, since CIGNA has long instructed us to bill telehealth with the POS code 02, and that is the current advice on their website right now. UPDATE: A provider forwarded me a March 5th email from Evernorth Provider Services urging providers to continue to use the 02 POS for telehealth services, as they have not adopted the POS 10 code.

First Choice: “n 2022 the POS for all telehealth will change to POS 10. For members with Medicare; POS code 10 will come into effect on April 1, 2022.” click here

Harvard Pilgrim: Click here

Humana: Click here

Kaiser: One Northern California provider received this response from Kaiser Provider Engagement: “The new 10 code is effective 1/1/22…so on all claims that the member is on a telehealth call from their home, use place of service 10. If the member is anywhere other than home, use 02.”

Magellan: Appears to be ready for the new code –for more info, click here

Medicare: May 9 update: Medicare states therapists should continue to use POS 11 (or the POS code had the session been in-person), even for telehealth sessions, until the end of the federal Public Health Emergency.  While they are processing claims with the 10 or 02 POS codes, providers are reporting that they are doing so at a reduced rate.  Medicare is urging therapists to continue to use POS 11 so that they can get reimbursed at the appropriate rate.  See my separate article on this topic at www.theinsurancemaze.com/medicarepos

MHN:  One provider stated “I have billed for sessions in January with MHN with POS 10 and included the 95 modifier and had the bills accepted and paid.”

OPTUM — see United

Regence — see Blue Cross and/or Blue Shield (above)

Tricare: It doesn’t seem to have switched yet — Since it is a federal plan, it will likely follow Medicare’s lead and not switch over until April 4 or later.  For Tricare West, see here.  For Tricare East/Humana, click here. 

Tufts of Massachusetts:  Accepting POS 10 as of 1/1/22

United Healthcare/United Behavioral Health/OPTUM – The plan seems to be accepting the new code, and providers are reporting they are being paid by these plans when using POS 10, though one provider stated when she called the plan they told her to continue using 02 for now.  Click here for more info

Wellcare – Yes — click here

“Is a POS code the same as a modifier?”  No.  A modifier is a two digit or two letter code that many health plans require following the CPT code for telehealth sessions.  You may still need a modifier even if you use a telehealth POS code.  While most health plans want the modifier 95 for telehealth (including Medicare), some want the older GT (e.g. Premera), and some accept both — ask the health plan.

“Where can I get a complete list of POS codes, in case I meet with clients at other locations?”  Just click here

“So, what’s your advice?”  I recommend you contact the health plan.  I plan to hold off using the POS 10 with any health plan until I get a clear go-ahead.  If you are going to try it, bill just one session soon afterwards so you can see how it goes.

In the meantime, it’s a great time to make some changes to your superbill/invoice. When doing telehealth sessions, it’s wise to include a POS code on superbills.  I recommend you add a column to your superbill so you can include the POS Code for each billed session.  While you are at it, add a column for telehealth modifier (95 or GT) that may need to be added to identify it as a telehealth session.  For a sample superbill perfect for telehealth or in-person sessions, see my Practice Forms Packet.

For more on proper telehealth billing, see my webinar “Telehealth Billing Post-COVID,” or schedule your personal consultation at www.calendly.com/barbgris.

If you have heard from other insurance plans, please share specific links and info with me!  Thanks! — click here