Pulmonology Coding Alert

Question: If our physician is performing interpretations for studies done at various hospitals from our office or any other location like his home, what POS needs to be used?

Georgia Subscriber

Answer: Reporting the correct POS (Place of service) code is important since reimbursements can vary depending on the setting where it was performed. For example, the payment made for some services rendered in an outpatient hospital facility can be lesser than when they are provided in a private office setting. This typically occurs when the facility receives separate reimbursement for the rendered service.

As per transmittals 1823 and 1873, CMS has come out with new guidelines that determine the POS for various services rendered by physicians who do not share a practice with the testing supplier. These guidelines came into effect from Jan 4, 2010. These guidelines have been formulated to enable proper coding of POS for various contracted services which has enabled the streamlining of excess payments made due to faulty POS codes.

If your physician shares a practice with the testing physician, then the place of service for the interpretation is the same as the testing physician. When the interpretation of services is provided by an "outside" physician, the following applies:

For all interpretations of studies done in an office setting for procedures that have been performed elsewhere, you have to code it under POS code 11 (Office). If the interpretation is done in the outpatient department of a hospital, then you should code it under POS code 22 (Outpatient hospital).

But, the issue becomes confusing if the interpretation is done in an office setting that is located within the hospital. If the office is a space that the physician has leased out from the hospital, then you will still continue to report it under code 11.

If the interpretations are being done from home, you will still have to code it under POS code 11 if relevant home information has been provided during enrollment of your physician with Medicare. Or else, the POS code 99 (Other place of service) is the code you need to go with. Exercise care while choosing POS code 99 as it might clash with the in-office exception of ancillary services that come under the purview of Stark Law.