Cardiology Coding Alert

Choosing the place of service (POS) can seem like a piece of cake -- until you realize the cardiologist interpreted a test at home. If you've never been sure whether your choice should reflect where the test took place, where the cardiologist interpreted the test, or some other option, help is here.

Why it matters: Medicare often pays physicians more for services in the office setting (where they incur more expense) than in facilities, so inappropriate use of POS 11 (Office) leads to Medicare shelling out more money that it should. The 2010 OIG Work Plan indicates the OIG will be scrutinizing physician POS coding for services in ambulatory surgical centers (ASCs) and hospital outpatient departments to catch POS 11 mistakes (http://oig.hhs.gov/publications/docs/workplan/2010/Work_Plan_FY_2010.pdf).

The OIG may not look specifically at your practice's claims for the Work Plan items, but knowing that the OIG is looking at these topics is important in general, advises Alli Larro, Esq., an Atlanta-based attorney.

The OIG usually samples claims from a prior year when it's performing its reviews, but you should still make sure your coding and billing processes for these claims are on the level going forward, says Stephanie  Fiedler, CPC, ACS-EM with Loeb and Troper in New York. That way you can be sure your future claims are accurate, and you can show any auditors that you take compliance seriously.

Try this: Be sure your POS choices match CMS's recent clarifications in Transmittal 1823 (www.cms.hhs.gov/transmittals/downloads/R1823CP.pdf), released Oct.2, 2009, and effective Jan. 4, 2010, says Marvel Hammer, RN, CPC, CCS-P, PCS, ACS-PM, CHCO, owner of MJH Consulting in Denver.

If the cardiologist performs the interpretation in her home, you may consider office POS 11 if it meets the definition of "office": "Location, other than a hospital, skilled nursing facility (SNF), military treatment facility, community health center, State or local public health clinic, or intermediate care facility (ICF), where the health professional routinely provides health examinations, diagnosis,and treatment of illness or injury on an  ambulatory basis." Whether the physician listed her home as a practice location in her enrollment information is key in deciding whether it's an office, the transmittal states.

If the home doesn't meet this definition, you should choose 99 (Other place of service).

For interpretations in a hotel room, don't choose POS 11 unless the hotel room meets the "office" definition and the physician's enrollment information lists it as an office. Another possibility is POS 16 (Temporary lodging) for an interpretation in the patient's hotel room. "If the hotel room is neither the office of the physician nor the temporary lodging of the patient then the appropriate POS is 'other' (POS 99)," the transmittal states.

Suppose the cardiologist interprets an ECG using telecommunications. "The POS code for a teleradiology interpretation is generally the place where the interpretation is read," the transmittal states. So if the cardiologist interprets the test at home, you would choose between 11 and 99, as described above.

An office is an office, according to this transmittal: "If the interpretation is performed in a location other than the main location of the physician group, and the location meets the definition of office, the POS code is office (11)." So if your cardiologist performs an interpretation in an office -- even if it isn't part of your practice or where the patient had the test -- you should still use POS 11.

For professional component claims of diagnostic tests performed under arrangement with a hospital, choose the POS based on where the cardiologist performs his portion of the service. For example, if he interprets the test in a hospital, look to POS 22 (Outpatient hospital), the transmittal states. But if he interprets the test in an office, you should choose POS 11.

Note: This transmittal updates Medicare Claims Processing Manual Chapter 26. Although this is national guidance, the updates also specify that contractors may provide direction when the POS may be unclear.