Wiki POS Question

[Aly13]

Hi, I am doing billing for a medical oncology practice that was just purchased by a hospital. I need to know what POS I am billing for commerical carriers. I know for Medicare/Medicaid I am using POS 22 but I have gotten so many conflicting answers from commerical carriers. We plan on doing split billing for Medicare/Medicaid (2 office visits) but what do commerical carriers have to say about that. HELP

Thanks
Peggy

 

[airart]

Pos

Hi Peggy,

Found this here on AAPC Website: states to Read CMS Transmittal 1823, Change Request 6375, issued October 2, for further details.

"Physicians who perform services in a hospital outpatient department should use POS code 22. Unless, that is, the physician maintains separate office space in the hospital or on hospital property that is not considered a provider-based department of the hospital. In that case, and providing the service was performed in the physician's office and not in the hospital, POS code 11 would be appropriate.

To clarify, CMS says, physicians who perform services for an ambulatory surgical center (ASC) should use POS code 24, not POS code 11. Only if the physician has an office at the ASC and the service is performed in the office would POS code 11 be appropriate. “However, no concurrent or overlapping hours can exist between the ASC and the physician's office,” CMS stipulates.

Remember: The POS code should coincide with the ZIP code identified on the claim form; and the ZIP code should coincide with the office practice location given in the physician's enrollment information. When in doubt, contact your Medicare contractor for guidance."

 

[Pam Warren]

If the practice has indeed retained the "practice" designation.....that is leasing space and paying overhead to the hosptial for use of the space, independent of the hospital's cost center, then they would remain POS 11. However, if the "practice" is under the umbrella of the hospital, with the facility taking over the maintenance, overhead, etc., of the space then you'd use POS 22. Since you're talking about split billing, I suspect you are an outpatient department of the hospital, and you'd use 22.

 

[Aly13]

Thank you very much for the help. One more question, since the drugs are being paid for by the hospital, the nurses are hospital employees, everything would be billed on a UB 04 with the doctors E/M visit code going on a HCFA 1500 correct? Thanks again for the help.

 

[Pam Warren]

yes, that's correct.

 

[Aly13]

I hate to be a pain but I need some additional assistance. My boss is insisting that I bill all non federal commerical carriers on a HCFA with POS 11 for all charges(infusions/drugs). For federal plans she has me billing them on a UB with POS 22. I can go along with billing the commerical plans on a HFCA but not with a POS 11. This seems total incorrect to me as the practice is owned and operated by the hospital. I feel like I am committing fraud. Is there anywhere that I can find where the guidelines are written so I can show her?
Thanks again for any and all help

 

[airart]

POS 22 vs POS 11

I found this MLN Article on POS and when to bill as appropriate. (MLN Matters #: MM7631)

NOTE: Physicians/practitioners who perform services in a hospital outpatient department will use, at a minimum, POS code 22 (Outpatient Hospital). Code 22 (or other appropriate outpatient department POS code as described above) will be used unless the physician maintains separate office space in the hospital or on the hospital campus and that physician office space is not considered a provider-based department of the hospital as defined in 42. C.F.R. 413.65. Physicians will use POS code 11 (office) when services are performed in a separately maintained physician office space in the hospital or on hospital campus and that physician office space is not considered a provider-based department of the hospital as defined in 42.C.F.R. 413.6. Use of POS code 11(office) in the hospital outpatient department or on hospital campus is subject to the physician self-referral provisions set forth in 42 C.F.R 411.353 through 411.357.