EM Coding Alert

Medicare Regulations:

Find Clarity on Medicare Telehealth POS Codes

Question: My provider sometimes uses technology to see Medicare beneficiaries in their homes, which sometimes are independent houses and other times in facilities where the patient is living long-term. I heard there was a place of service (POS) change for Medicare but am not sure what it is; could you help?

Delaware Subscriber

Answer: Beginning January 1, 2024, providers receive either the facility or nonfacility payment rate for eligible Medicare telehealth services, depending on the POS code the billing specialist selects. As of the same date, there are only two POS codes that are valid for Medicare telehealth billing, according to Chapter 26 of the Centers for Medicare & Medicaid Services (CMS) Medicare Claims Processing Manual. They are:

  • POS 02: “The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.” This is paid at the facility rate.
  • POS 10: “The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.” This is paid at the nonfacility rate.

Note these caveats: “As appropriate, POS 02 or POS 10 may be used and must be paired with the appropriate telehealth modifier (modifier 93 for audio-only and modifier 95 for audio/video) … Use of audio-only (93) or audio-video (95) does not change rate of payment, only the POS code determines the non-facility or facility payment rate,” CMS says.

Rachel Dorrell, MA, MS, CPC-A, CPPM, Development Editor, AAPC