Cardiology Coding Alert

Master the definition of campus to avoid errors.

You already know that there are changes coming January 1 to outpatient place of service codes if you read Cardiology Coding Alert, vol. 8, no. 10, “Prepare to Use POS 19 for Off Campus Outpatient Hospital Services.” Here are a few more details to fill in the blanks.

Understand off-campus: CMS announced Aug. 6 (Change Request 9231 to the Medicare Claims Processing Manual) that it was creating new POS code 19 to identify off-campus outpatient services. CMS defines a campus as “the physical area immediately adjacent to the provider’s main buildings, other areas and structures that are not strictly contiguous to the main buildings but are located within 250 yards of the main buildings and any other areas determined on an individual case basis, by the CMS regional office, to be part of the provider’s campus” says Michael Granovsky, MD, FACEP, CPC, President of LogixHealth, a national coding and billing company based in Bedford, Mass. The CR is available at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3315CP.pdf.

Effective Jan. 1, 2016, you will start to use the current POS code 22 exclusively for services rendered in outpatient settings on the campus of the main hospital, such as outpatient clinics, he adds.

CMS wants to better track which outpatient services were provided in off-campus provider-based settings to evaluate the practice expense associated with those venues.

CMS states that POS code 19 will follow the same payment policies as the current POS code 22, including the three day rule under which services provided to patients at wholly-owned physician practices that take place within three days of a hospital admission are considered bundled into the payment for the admission, notes Granovsky.