Telehealth Place of Service Coding Changes
The Centers for Medicare and Medicaid Services (CMS) recently made changes to The Place of Service (POS) code set. The POS code set provides setting information necessary to pay claims correctly. The CMS POS Workgroup revised the description of POS code 02 and created a new POS code 10 to meet overall industry needs. The new POS code was effective January 01, 2022.
1. POS 02: Telehealth Provided Other than in Patient’s Home
Descriptor: The location where health services and health related services are provided or received, through telecommunication technology. Patients are not located in their home when receiving health services or health related services through telecommunication technology.
2 . POS 10: Telehealth Provided in Patient’s Home
Descriptor: The location where health services and health related services are provided or received through telecommunication technology. Patients are located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
While CMS did not recognize the need for the new place of service code within their own billing guidelines, they did recognize the need for greater specificity for the health care industry.
Areas of Interest:
The enhanced specificity to the POS adds an additional element for analysis for fraud, waste, and abuse. More specifically, it provides an opportunity to analyze where patients are located when receiving telehealth services at the time of service compared to the previous traditional telehealth indicators.
According to a report (OEI-02-20-00521) from the Health and Human Services, Office of Inspector General, most Medicare beneficiaries received telehealth services only from providers with whom they had an established relationship. Additionally, beneficiaries saw providers in person for about 4 months prior to their first telehealth service, on average. The report noted that the proportion of beneficiaries receiving telehealth services varied by type of service.
This data snapshot can be used to inform decisions about how to best use telehealth for policy considerations. Specifically, decisions about which services are allowed to be delivered via telehealth on a more permanent basis and the extent that beneficiaries should have a relationship with their providers prior to receiving certain telehealth services.
Things to monitor:
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- Beneficiaries with high units of service through multiple places of service on the same date of service
- Beneficiaries with overlapping POS 02 and 10 codes on the same date of service.
- Consecutive days of telehealth for beneficiaries.
- Trends/baselines prior to new POS code 10 being implemented compared to current utilization.
- High number of beneficiaries receiving treatment without an established prior relationship with the provider
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References:
- https://www.cms.gov/files/document/mm12427-newmodifications-place-service-pos-codes-telehealth.pdf
- https://oig.hhs.gov/oei/reports/OEI-02-20-00521.asp
