The Centers for Medicare and Medicaid Services (CMS) has once again issued new guidance on the delivery of health care services during the COVID-19 public health emergency.

Effective March 31, 2020, psychologists providing services through telehealth should use the place of service (POS) that would have been reported if the service had been furnished in-person. CMS is making this change to identify when it is appropriate to pay a nonfacility fee, rather than a facility fee which would have automatically been included under POS 02.

To illustrate, a psychologist who would have seen patients in a private office should use POS 11. Those who would have treated the patient in a clinic or skilled nursing facility should use the corresponding POS.

All claims for telehealth services should now include modifier 95.

For more information on billing for Medicare beneficiaries during the public health crisis, please see our expanded coverage.