# Place of Service - For Independent Labs



## Hisham.I@synergenhealth.com

Dear All,

Would you happen to know what the place of service should be for the services done at an independent lab? The Medicare claims processing manual states it should be the location that draws the testing specimen. However from my personal experience I've seen a lot of laboratories bill the place of service as 81- independent lab although the specimen was drawn at a clini/physician's office (POS -11).

Appreciate any thought on this.

Thank you!


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## tsalomonson

*Independent Laboratory Place of Service*

Our office has been trying to determine the same thing.  We have had denials from 2 payers who state the POS on the claim should be the location where the "face-to-face encounter" took place or the specimen was collected. I reached out to CMS on May 22nd and below is the response that I recevived. 
Thank you for your inquiry regarding independent laboratories and place of service (POS) codes.

"The Medicare Claims Processing Manual, Chapter 26, Section 10.6 states the following:

If the physician bills for a lab service furnished by an independent lab, the code for "Independent Laboratory" is used. Items 21 and 22 on the Form CMS-1500 must be completed for all laboratory work performed outside a physician's office. If an independent lab bills, the place where the sample was taken is shown. An independent laboratory taking a sample in its laboratory shows "81" as place of service. If an independent laboratory bills for a test on a sample drawn on an inpatient or outpatient of a hospital, it uses the code for the inpatient (POS code 21), off campus-outpatient hospital (POS code 19), or on campus-outpatient hospital (POS code 22), respectively.

The Medicare Claims Processing Manual, Chapter 26 can be found at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c26.pdf.

For additional information, please visit the Medicare Learning Network website below:
http://www.cms.gov/Outreach-and-Edu...LN/MLNGenInfo/index.html?redirect=/MLNGenInfo.

I hope this information is helpful."

I do know that other independent labs are facing the same dilemma. There is confusion because CMS CR 7631 dated March 29, 2013 states "clarification on POS for patholgy and laboratory services will be provided through another change request". I found CMS MM8399 which relates to the TC of Pathology Services ocurring on the same DOS as an Outpatient Hospital visit but I did not see another document that was released by CMS that would provide the clarification needed. 

If I was to go by the email response from Medicare, an Independent Laboratory who does not see patients would NEVER use POS 81.  One of the issues we are having is trying to decide if the MAC is following the same rule. If our claims are billed with an 81 POS, why would the MAC not deny our claims?

At this point, I don't know what place of service to use on our claims. We receive specimens from Physicians Offices, Outpatient Hospitals (both On and Off Campus) and Inpatient Hospitals.

Hopefully, someone will be able to respond to this post and provier clairification.

Thank you!


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## karamac

*Place of Service*



tsalomonson said:


> Our office has been trying to determine the same thing.  We have had denials from 2 payers who state the POS on the claim should be the location where the "face-to-face encounter" took place or the specimen was collected. I reached out to CMS on May 22nd and below is the response that I recevived.
> Thank you for your inquiry regarding independent laboratories and place of service (POS) codes.
> 
> "The Medicare Claims Processing Manual, Chapter 26, Section 10.6 states the following:
> 
> If the physician bills for a lab service furnished by an independent lab, the code for "Independent Laboratory" is used. Items 21 and 22 on the Form CMS-1500 must be completed for all laboratory work performed outside a physician's office. If an independent lab bills, the place where the sample was taken is shown. An independent laboratory taking a sample in its laboratory shows "81" as place of service. If an independent laboratory bills for a test on a sample drawn on an inpatient or outpatient of a hospital, it uses the code for the inpatient (POS code 21), off campus-outpatient hospital (POS code 19), or on campus-outpatient hospital (POS code 22), respectively.
> 
> The Medicare Claims Processing Manual, Chapter 26 can be found at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c26.pdf.
> 
> For additional information, please visit the Medicare Learning Network website below:
> http://www.cms.gov/Outreach-and-Edu...LN/MLNGenInfo/index.html?redirect=/MLNGenInfo.
> 
> I hope this information is helpful."
> 
> I do know that other independent labs are facing the same dilemma. There is confusion because CMS CR 7631 dated March 29, 2013 states "clarification on POS for patholgy and laboratory services will be provided through another change request". I found CMS MM8399 which relates to the TC of Pathology Services ocurring on the same DOS as an Outpatient Hospital visit but I did not see another document that was released by CMS that would provide the clarification needed.
> 
> If I was to go by the email response from Medicare, an Independent Laboratory who does not see patients would NEVER use POS 81.  One of the issues we are having is trying to decide if the MAC is following the same rule. If our claims are billed with an 81 POS, why would the MAC not deny our claims?
> 
> At this point, I don't know what place of service to use on our claims. We receive specimens from Physicians Offices, Outpatient Hospitals (both On and Off Campus) and Inpatient Hospitals.
> 
> Hopefully, someone will be able to respond to this post and provier clairification.
> 
> Thank you!



Oh Place of Service.. so this will depend on the type of service and also where the patient was seen.  It can get pretty complicated with your laboratory is a clinical outreach lab as part of a hospital system.  Without asking you alot more questions on the forum, it would be best to give me a call.. my number is below and I can see if I can help.. If not I have another resource who I may be able to refer you to...


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## anascout

Hello,

I was wondering if you would be able to offer advise on the correct place of service for a pathology lab processing tissue collected by dermatologists in their offices. If we do not collect samples at out lab location, would we still be an independent lab?
Any help is appreciated.

Thank you!



karamac said:


> *Place of Service*
> 
> 
> 
> Oh Place of Service.. so this will depend on the type of service and also where the patient was seen.  It can get pretty complicated with your laboratory is a clinical outreach lab as part of a hospital system.  Without asking you alot more questions on the forum, it would be best to give me a call.. my number is below and I can see if I can help.. If not I have another resource who I may be able to refer you to...


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