Oncology & Hematology Coding Alert

Be definitive for campus services and prepare to welcome a new code.

In 2015, the outpatient hospital place of service (POS) code is 22. Effective Jan. 1, 2016, and to be implemented on Jan. 4, 2016, you will have two updated POS codes to consider for outpatient services.

The background published in Transmittal 3315/Change Request 9231 on Aug. 6, 2015 seems to indicate Medicaid contractors may need to better track outpatient hospital billing provided in off-campus v. on-campus provider-based settings. It is also noted that the 2016 OIG Work Plan includes an indication CMS will continue oversight of provider based locations because of the concern of higher costs to the Program stating, “Provider-based status can result in higher Medicare payments for services furnished at provider-based facilities and may increase beneficiaries’ coinsurance liabilities. The Medicare Payment Advisory Commission (MedPAC) has expressed concerns about the financial incentives presented by provider-based status and stated that Medicare should seek to pay similar amounts for similar services.”

Understand Off-Campus

CMS announced on Aug. 6, 2015 that it was creating new POS code 19 to identify off-campus outpatient 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,” says Michael Granovsky, MD, FACEP, CPC, President of Logix Health, a national coding and billing company based in Bedford, Mass. The CR is available at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3315CP.pdf.

Confirm Off-Campus vs. On-Campus

Carefully read and understand what the descriptors talk about POS 19 and POS 22.

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. Effective Jan. 1, 2016, you will start to use the current POS code 22 only for services rendered in outpatient settings on the campus of the main hospital, Granovsky says.

Check Payment Policies

CMS states that POS code 19 will follow the same payment policies as the current POS code 22, including the three day rule. Under this rule, payments for services provided to outpatients later admitted within three days of a hospital admission are considered bundled into the payment for the hospital inpatient admission, notes Granovsky.

Resource: Check out the MLN Matters article fromCMS about the new POS codes: www.cms.gov/Outreachand-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9231.pdf.http://www.cms.gov/Outreachand-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9231.pdf.