With recent changes in telehealth coding guidance put forth by the Centers for Medicare & Medicaid Services (CMS) and alterations to guidance relating specifically to the ongoing COVID-19 public health emergency (PHE), proper coding can be a challenge.
APA has noted confusion around Point of Service (POS) coding for telehealth during the PHE. In addition, CMS recently released new information about the in-person visit requirement for mental health services added through federal legislation.
Some of the confusion relates to CMS putting forth guidance regarding POS codes for telehealth, but not placing this in the context of how providers in Medicare have been instructed to bill for telehealth during the PHE, which has been extended until April 16, 2022, and may be extended further.
In Medicare, telehealth providers have been instructed to use POS 11 along with modifier 95 during the PHE. This is to insure that during the PHE providers are reimbursed at the higher nonfacility rate. For details about facility versus nonfacility rates, please see: Telehealth after the pandemic: CMS outlines proposed changes.
APA believes the intent of CMS’s recent change (Change Request 12427) is to provide a standard code set for differentiating between telehealth received at a typical originating site (POS 02) versus telehealth received in the home (POS 10). These POS options can also be used by other payers to differentiate where the service is received. Please check directly with commercial insurers and Medicaid to determine their policies about POS coding for telehealth.
Changes to the POS codes for 2022 are outlined below.
|02||Telehealth provided other than in patient’s home||
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.
Effective January 1, 2017.
Description change effective January 1, 2022, and applicable for Medicare April 1, 2022.
|10||Telehealth provided in patient’s home||
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.
This code is effective January 1, 2022, and available to Medicare April 1, 2022.
Medicare has communicated that Change Request 12427 is not requiring Medicare providers to change anything on how they are currently billing their telehealth claims during the PHE.