ED Coding and Reimbursement Alert

Provider-based settings away from hospitals to get their own POS code in 2016.

Although the emergency department place of service (POS) code 23 has not changed, there will be a new POS code for services rendered at outpatient settings that are not part of the main hospital campus starting Jan. 1, 2016.

CMS announced Aug. 6 (Change Request 9231 to the Medicare Claims Processing Manual) that it was creating new POS code 19 to identify those off-campus 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 ED coding and billing company based in Bedford MA.

The current POS code 22 will now be used exclusively for services rendered in outpatient settings on the campus of the main hospital, such as outpatient clinics, he adds.

The Modifier Approach Was Modified

The modifier solution will be replaced with a POS code for 2016. CMS said it needed to better track which outpatient services were provided in off-campus provider-based settings to evaluate the practice expense associated with those venues. In the 2015 Medicare physician fee schedule, this would be done with a modifier that would have been appended to the both facility and professional services; however, it has chosen to accomplish this goal with a POS code instead.

CMS states that POS code 19 will follow the same payment policies as the current POS code 22 (On campus outpatient hospital), 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.