AI Alert March 2024

Taking Medicine To The Street – Reimbursement Now Available For Street Medicine 

Starting October 1, 2023, providers can report street medicine services using the newly established Place of Service (POS) code 27, as created by CMS. This place of service is defined as “a non-permanent location of the street or found environment, not described by any other POS code, where health professionals provide preventive, screening, diagnostic, and/or treatment services to unsheltered homeless individuals”. CMS characterizes street medicine services as Part B services. Physicians will be reimbursed a non-facility rate for services rendered. Street medicine is distinguished from other places of services such as Mobile (POS 15), which is defined as a facility/unit that moves from place-to-place equipped to provide preventive, screening, diagnostic, and/or treatment services.    

Street medicine represents a promising strategy for providing comprehensive services when and where persons experiencing homelessness need them. Innovative payer solutions such as shared-savings or global risk models might be on the horizon to control cost effectively. Many of the unhoused are already enrolled in Medicaid but not all. With the ability to be reimbursed for street medicine services, lobbyists are campaigning for higher payment rates. Street medicine services may include: 

• Primary care services 
• Vaccine administration 
• Wound care 
• Preventive services 
• Counseling 
• Medication for treatment of opioid use disorder or medication assisted treatment 
• Diagnostic services such as rapid blood screening for diabetes and high cholesterol or rapid Covid-19 and flu testing 

Providers eligible to submit for reimbursement include: 

• Physicians 
• Certified registered nurse practitioners 
• Certified nurse midwives 
• Advanced practice clinicians  
• Physician assistants 
• Psychologists 
• Mobile mental health treatment providers 

**registered nurses are not individually included in the provider list 

While street medicine allows early intervention and easier access to healthcare services, there are concerns about the lack of oversight. Street medicine providers will be held to the same standard as any healthcare facility delivering medical care, which includes clinical record keeping. Oversight challenges of street medicine may include: 

• Lack of clear organizational structures and chain of command 
• Unavailability to electronic medical records and data tracking system on the streets (street encounters can be documented in the home institution’s EMR) 
• Medication dispensing and safety guidelines 
• Lack of standard referral procedures and protocols to ensure timely access to continuity of primary care 
• Providers treating patients for conditions that are not within the provider’s regular scope of practice 

What potential fraud, waste, and abuse scenarios should payers consider for street medicine claims? 

Fraud, waste, and abuse can happen in any type of healthcare billing. Payers should monitor and analyze their claims data to determine the population of claims related to street medicine and look for patterns that might cause concerns. Some of those possible concerns might be: 

• Trends that identify high utilization of visits per patient 
• Billing for surgical procedures that would seem unlikely to be performed outside of a clinical setting, i.e., anesthesia services 
• Increased volume of Commercial claims billed with POS 27  
• Billing of services not performed by credentialed staff 
• Excluded providers billing for street medicine services 
• Lack of documentation to support billing for street medicine 
• Services from providers that are normally are billed in mobile units such as PET scans or radiology exams 
• Providers billing for street medicine (POS 27) and billing claims from an office setting or other locations 

References: 

Street Medicine: Barrier Considerations for Healthcare Providers in the U.S. 

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10250111/

CMS Manual System – Medicare Claims Processing, Change Request 13314 

https://edit.cms.gov/files/document/r12411cp.pdf

Medicare Claims Processing Manual Chapter 26 – Completing and Processing Form CMS-1500 Data Set 

https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c26pdf.pdf