General Surgery Coding Alert

Save POS 22 for on campus.

As of January 1, you should have a new place-of-service (POS) code in your surgical reporting toolbox.

While you’ve been used to reporting POS 22 for all hospital outpatient services, you now must choose one of the following indicators:

• POS 19 (Off Campus - Outpatient Hospital) Descriptor: A portion of an off-campus hospital provider based department which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.
• POS 22 (On Campus - Outpatient Hospital)
  

Descriptor: A portion of a hospital’s main campus which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.

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.

Know the Update Logic

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.

Resource: Check out the MLN Matters article from CMS about the POS codes: www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9231.pdf.