In October of 2021, the Center for Medicare & Medicaid Services (CMS) announced changes to the Place of Service (POS) codes used on claims for telehealth encounters. If your practice bills for any telehealth (or “telemedicine”) encounters, you should learn about the changes and discuss them with your payers. You may need to update your PCC configuration.
CMS changed the description of POS 02 to “Telehealth Provided Other than in Patient’s Home”, and introduced POS 10, “Telehealth Provided in Patient’s Home”. The effective date is January 1st, 2022, and the implementation date is April 4th, 2022.
Watch a Video Overview: You can watch an overview video explaining the POS code changes and PCC configuration: Configure Your Telemedicine Place of Service Codes (2022).
- 1 Learn the Details of the New and Updated POS Codes
- 2 Configure PCC So the Right Place of Service Code(s) Appear on Your Claims
- 3 Automatically Use Telemedicine Place of Service Code 10 in PCC EHR
Learn the Details of the New and Updated POS Codes
CMS now defines these two telemedicine place of service (POS) codes:
- POS 02: Telehealth Provided Other than in Patient’s Home
Descriptor: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
- POS 10: Telehealth Provided in Patient’s Home
Descriptor: The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
For more details, you can review the full CMS Place of Service Code Set.
Configure PCC So the Right Place of Service Code(s) Appear on Your Claims
How Were Pediatric Practices Billing Telemedicine Encounters Prior to This Update?
Prior to this change, payers typically required the Place of Service code 02 on claims for telemedicine encounters.
When PCC helped practices configure their locations for telemedicine billing, we typically recommended cloning an existing in-office location in your PCC configuration tables to create a secondary telemedicine place of service, which would use the 02 code. Your practice can also configure PCC EHR to automatically select a telemedicine location for appointments marked “Telemedicine”, so all of a clinician’s time could be scheduled for a single office location.
What POS Claim Configuration Changes Will Practice Make in 2022?
Depending on what you learn from your payers, your practice may decide to:
- Clone your telemedicine entry in your Place of Service table (see Configure PCC EHR for Telemedicine Encounters) to create a new entry.
- Give the new entry a Place of Service code of 10.
- Adjust the names of your locations for ease of use. For example:
Your practice can then select the appropriate location when you post charges, distinguishing between telemedicine encounters where the patient is at home (POS 10) or located somewhere else (POS 02).
Talk to Your Payers First!: It is not clear how or when payers will expect pediatricians to use these adjusted POS codes. CMS indicates the “effective” and “implementation” dates for their purposes (January 1st and April 4th, 2022, respectively), but we do not know how payers will respond and what POS codes they will require. Your practice should ask your major payers about appropriate coding for telemedicine visits.
Clone, Don't Overwrite: When you edit your location configuration, remember to clone your existing telemedicine location to create a new entry. Do not overwrite your existing location’s POS code (02). When you change an existing location, you may inadvertently be editing claim history and previous claims that may need to be reviewed and/or resubmitted.
Automatically Use Telemedicine Place of Service Code 10 in PCC EHR
In anticipation of practices needing Place of Service (POS) code 10 some time in 2022, PCC will update PCC EHR to see both 02 and 10 as available for telemedicine visits. This will support ease of use functionality when your practice schedules and post charges in PCC EHR.
For example, you will be able to map a practice location’s default telemedicine location to any place of service with an 02 or a 10.
Also, when your practice’s biller posts telemedicine encounters, they will be able to select among all the telemedicine locations (02 or 10) configured on your system. (For PCC EHR 9.2 and prior, you can configure default telemedicine places of service that have an 02 code.)
We’ll be rolling these adjustments out in PCC 9.3, arriving to all practices in the first quarter of 2022.
What If Your Practice Needs POS 10 to Appear on Claims Earlier than PCC 9.3?: If you learn from a payer that your telemedicine encounters need POS 10 prior to your update to PCC 9.3, PCC can accommodate that as well. Speak with a PCC Support representative to discuss options, which could include 1) update encounter’s place of service later (Change an Encounters Billing Place of Service), 2) post Telemedicine encounters in the patient’s Billing History (Post a Billing Encounter) ), 3) post telemedicine encounters in the previous Partner charge posting tool (Post Encounter Charges in Partner), or 4) work with PCC’s EDI specialists to automatically adjust the POS code on claims for certain payers.
Charting a Patient's Location: Your practice may wish to begin charting a patient’s location during telemedicine encounters. You can do so by adjusting your telemedicine chart note protocols to include a custom component.