Medicare Compliance & Reimbursement

Meanwhile, stick to using the code applicable to the patient’s location.

In addition to all the newly proposed telehealth services that Medicare will likely cover starting next year, the Centers for Medicare & Medicaid Services (CMS) is also contemplating creating a brand-new place of service (POS) code for telehealth. Here’s what you need to know.

Background: “POS codes impact practitioner reimbursement and are used on professional claims to specify the location where services are rendered,” according to attorneys Marshall Jackson, Jr. and Dale Van Demark of McDermott, Will & Emery. “Currently, there is no POS code specific for telehealth services; however, CMS received several requests to establish a POS code specifically for telehealth services.”

The POS Workgroup officially establishes policies for POS code usage, but CMS has proposed various modifications to existing policies for reporting telehealth services, wrote attorneys Laura Little, Cybil Roehrenbeck, and Sidney Welch of Polsinelli LLP in a July 22 brief. Nevertheless, in the proposed rule “CMS proposed various modifications to existing POS codes policies for reporting telehealth services to allow for possible future POS Workgroup decisions governing appropriate coding, which might occur before Jan. 1, 2017.”

Specifically, CMS wants to require practitioners providing telehealth services to report the POS code they would use if they had furnished the services in-person (the patient location). This would indicate that the practitioner provided the services via telehealth.

What to expect: In the meantime, CMS suggested that POS code usage for the originating site remain unchanged, so that the originating site should continue to bill for the facility fee and continue to use the POS code applicable to the patient’s location (facility or non-facility) to receive the correct reimbursement rate, the Polsinelli attorneys explained.

CMS also proposed using the facility practice expense relative value units (PE RVUs) to reimburse for the telehealth services, Jackson and Van Demark note. Using the POS code applicable to the patient’s location, the provider would correctly receive the reimbursement rate of either the facility PE RVU or the non-facility PE RVU.