Place of Service (POS) CMS List Coding Instructions Revised (CR7631).

Every physician or other provider encounter requires a place of service (POS) code for proper claims processing.  But how should a physician determine their point of service? The Centers for Medicare and Medicaid Services (CMS) put an end to that question once and for all with Change Request 7631.  Apparently, there have been too many errors over too many years with physicians and other providers reporting the wrong site of service location.  

As far as I can tell, this Change Request 7631 was originally submitted March 29th, 2012 under Transmittal 2435 in the CMS Manual System.  Transmittal 2435 was replaced by Transmittal 2561 on September 28th, 2012,  which was replaced by Transmittal 2563 on October 11, 2012, which was replaced by transmittal 2613 on December December 14th, 2012, which was finally replaced by Transmittal 2679 on March 29th, 2013 in the CMS Manual System.  But we're not done yet folks.  CMS says in transmittal 2679 they will discuss place of service for laboratory and pathology services through another change request at a later date.  Yes folks, single payer government Medicare efficiency is alive and well.

Transmittal 2679 establishes a national policy for the correct place of service code assignment.  CMS has a table of all POS codes that are used by all Medicare contractors, Medicaid and private insurance companies as well.  Each POS code is defined as a facility or nonfacility place of service for payment purposes under the Medicare Physician Fee Schedule (MPFS).   In the now rescinded December 11, 2009 Transmittal 1873, physicians were instructed to submit their two digit place of service based on their physical location during when providing the service (the service location).

This has now changed.  With only two exceptions, the place of service code shall now be the same location the beneficiary received their face-to-face service.  In cases where a face-to-face encounter is removed (such as providing the professional component in the interpretation of a diagnostic test) at a distant site, the POS code for the professional component shall be determined by the setting in which the technical component was provided.  The two exceptions to this face-to-face provision rule defined in Transmittal 2679 are defined as follows:
"For a service rendered to a patient who is an inpatient of a hospital (POS code 21) or an outpatient of a hospital (POS code 22), the facility rate is paid, regardless of where the face-to-face encounter with the beneficiary occurred"
But don't even think about moving to India or contracting with a bunch of radiologists from India. Medicare will not pay for your service. It says so right in Section 60 of this manual:
Payment may not be made for a medical service (or a portion of it) that was subcontracted to another provider or supplier located outside the United States. For example, if a radiologist who practices in India analyzes imaging tests that were performed on a beneficiary in the United States, Medicare would not pay the radiologist or the U.S. facility that performed the imaging test for any of the services that were performed by the radiologist in India.
Place of service codes carry a number between 01 and 99.   You can find the definitions of each POS code in Chapter 26 of the Medicare Claims Processing Manual (Section 10.5 starting on page 20).  They can be divided in to two main categories of payment:  facility payment rate and nonfacility payment rate.   The settings where point of service codes are paid at the facility rate are
  • Inpatient hospital (POS code 21)
  • Emergency room hospital (POS code 23)
  • Medicare participating ASC (POS code 24)
  • Skilled Nursing Facility for a Part A resident (POS code 34)
  • Ambulance on land (POS code 41)
  • Ambulance on air or water (POS code 42)
  • Inpatient psychiatric facility (POS code 51)
  • Community mental health center (POS code 53)
  • Psychiatric residential treatment center (POS code 56)
  • Comprehensive inpatient rehabilitation center (POS code 61)
Physician's services are paid at the nonfacility rate at the following point of service locations
  • Pharmacy (POS code 1)
  • School (POS code 3)
  • Homeless shelter (POS code 4)
  • Prison/Correctional Facility (POS code 9)
  • Home or private residence of patient (POS code 12)
  • Assisted living facility (POS code 13)
  • Group Home (POS code 14)
  • Mobile Unit (POS code 15)
  • Temporary lodging (POS code 16)
  • Walk-in retail health clinic (POS code 17)
  • Urgent care facility (POS code 20)
  • Birthing center (POS code 25)
  • Nursing facility and SNFs to part B residents (POS code 32)
  • Custodial care facility (POS code 33)
  • Independent clinic (POS code 49)
  • Federally qualified health center (POS code 50)
  • Intermediate health care facility/mentally retarded (POS code 54)
  • Residential substance abuse treatment facility (POS code 55)
  • Non-residential abuse treatment facility (POS code 57)
  • Mass immunization center (POS code 60)
  • Comprehensive outpatient rehabilitation facility (POS code 62)
  • End-stage renal disease treatment facility (POS code 65)
  • State or local health clinic (POS code 71)
  • Rural health clinic (POS code 72)
  • Independent laboratory (POS code 81)
  • Other place of service (POS code 99)
All of the above information has been nicely packaged into an easy to read MLN Matters publication for your quick and easy review, should you wish to proceed.  Because most of you don't care, I've taken the liberty of contacting CMS myself for better clarity on POS code 99.  They have agreed POS code 99 needs better clarity and have asked The Happy Hospitalist to use his influence to further the data mining expedition known as The Medicare National Bank.   In addition to these widely publicized point of service codes, CMS has contracted with The Happy Hospital to help further clarify "other place of service" codes as part of an effort to make the roll out of ICD-10 even more thorough.  Here is a list of recently approved point of service codes that will be included on the absolute most final transmittal ever, or at least until the next one is made.  
  • Cardiac arrest anywhere (POS code blue)
  • Cardiac arrest at a movie theater (POS code Blues Brothers)
  • GI endoscopy suite (POS code brown)
  • At an accountant's office (POS tax code)
  • At a medical coder's office (POS over coding)
  • At an FBI office (POS secret code)
  • At a CIA office (POS crack the code)
  • At Google Maps headquarters (POS zip code)
  • At the Friday night dance with the elderlies club (POS no code)
  • At a software convention (POS source code)
  • At a Department of Defense (POS morse code)
  • At a lawyers convention (POS code of conduct)
  • At a convention of conspiracy theorists (POS Da Vinci code)
  • In a supermarket (POS bar code)
  • In a childs playground (POS code word)
  • At war (POS code of honor)
  • At a boarding school (POS dress code)
  • At a construction site (POS building code)
Any questions?

Some of this post is for entertainment purposes only and likely contains humor only understood by those in a healthcare profession. Read at your own risk. 

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