Practice Management Alert

Fewer than 25 percent of practices nail the correct POS for facility-rendered services

Billers who think place-of-service (POS) codes don't deserve a second look are in for a rude awakening - and potential fraud or abuse charges.
 
When the HHS Office of Inspector General (OIG) recently reviewed Trailblazer and Empire Medicare, the agency revealed that 75 to 88 percent of sampled practices were reporting office setting POS codes for facility-rendered physician services. Because nonfacility fees are higher to compensate for staff and practice overhead, Medicare may have overpaid Empire alone more than $1.4 million between 2000 and 2002.
 
You need to take action: To help you steer clear of disaster, our experts answer three of your most pressing POS questions to help you choose the right code to fill Box 24B on the CMS 1500 form. 1. Question: What criteria should I use to differentiate between POS 31 (Skilled nursing facility), 32 (Nursing facility) and 33 (Custodial care facility) when dealing with nursing facilities? Answer: The confusion surrounding these three codes arises because a facility can have both skilled nursing and nonskilled nursing beds at the same time.
 
31: You should use skilled nursing facility code 31 when your physician treats a patient who is in a skilled bed at the time of service. This means the patient has a medical condition that requires skilled nursing care, such as injections or ventilation. Medicare must authorize skilled nursing services and considers them a Medicare Part A expense.
 
A patient is allowed only a certain number of SNF days per year, says Kathleen Jillson, director of practice administration at Erickson Retirement Communities in Catonsville, Md. If a nursing facility brings a patient to the physician's office, you should report POS code 11 (Office) on the claim form.
 
32: You should choose nursing facility POS code 32 if the patient is not on Part A Medicare, but instead is on long-term care and receiving medical, nursing or rehabilitative services.
 
Because determining what type of bed the patient has can be difficult, you need to maintain close communication with the administrative or billing office in the nursing facility to determine whether the patient is in a skilled bed when a physician sees a patient there, says Barbara J. Cobuzzi, CPC, CPC-H, CHBME, president of Cash Flow Solutions Inc. in Brick, N.J.
 
33: You would report POS code 33 for a custodial care facility. These facilities provide patients with personal assistance services on a long-term basis, but do not provide medical care (although they do provide assistance, such as dispensing medications). Patients are mobile in a custodial care facility, so there must be medical necessity for a physician to see a patient at the facility and not in his office.
 
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