Pathology/Lab Coding Alert

Reader Questions:

Use Patient Location for POS

Published on Mon Apr 11, 2022

Question: We’ve been getting denials for COVID-19 test claims with the statement “The procedure code/bill type is inconsistent with the place of service.” We’re using POS code 81 because we’re an independent lab. Someone told me we should be using 69. Is that correct?

Pennsylvania Subscriber

Answer: You should not be using place of service (POS) code 81, Independent Laboratory, for tests you perform in your independent lab. Code 69, Clinical laboratory (billing independently), is not a POS code, but is a Medicare provider specialty code, so you shouldn’t use that, either.

Do this: You should submit claims using the POS code for the patient’s location when the specimen is taken. That means you’ll likely use one of the following POS codes instead of 81, especially for COVID-19 tests:

01, Pharmacy
11, Office
13, Assisted Living Facility
17, Walk-in Retail Health Clinic
20, Urgent Care Facility
21, Inpatient Hospital
22, On Campus - Outpatient Hospital
31, Skilled Nursing Facility
71, Public Health Clinic
72, Rural Health Clinic

Resources: For a list of POS codes and instructions for reporting them, see the Medicare Claims Processing Manual, Chapter 26, available at https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c26pdf.pdf.