CMS Clarifies the Point of Service Coding Instructions

On September 28, CMS issued Transmittal 2156 revising and clarifying Place of Service Coding (POS) instructions. The Transmittal rescinds previous Transmittal 2435, extends the implementation date to April 1, 2013 and provides a few clarifications for physicians and other supplier entities when determining the appropriate Point of Service (POS) designation for Physicians and Supplier entities. Specifically, this transmittal clarifies the following:

• Global billing is only permissible when the physician providing the professional component (PC) and technical component (TC) are the same and both services are located in the same payment locality.

• For non-global billing, the POS is where the TC was provided, but the claim must include name and address of the physician or other supplier providing the PC.

• The PC services must be billed to the locality where the services were provided, unless the services were provided in an unusual place, such as a hotel.

• Services provided to a registered inpatient or hospital outpatient must at minimum use the relevant POS codes (POS 21 for inpatient and POS 22 for outpatient). If the specific location (skilled nursing facility, emergency room, ambulatory surgical center, etc.) of the beneficiary is known, the appropriate code for that setting may be used.
CMS will issue release a separate transmittal for pathology services.

For more information, please contact Adrienne Dresevic, Esq. at (248) 996-8510 or visit the HLP website.

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