When billing for outpatient medical services, choosing the correct Place of Service (POS) code can make or break your reimbursement. Among the most debated are POS 2 (Telehealth Provided Other than in Patient’s Home) and POS 10 (Telehealth Provided in Patient’s Home). These two codes may seem similar, but their implications for billing, reimbursement, and compliance are quite different.
This guide breaks down the nuances between POS 2 and POS 10 in a way that’s clear, deep, and easy to understand. We’ll also bring in CMS guidelines and real-world examples to help you bill accurately and optimize your claims.
What is Place of Service Code 2?
POS 2: Telehealth Provided Other than in Patient’s Home
- Used when telehealth services are delivered to a patient not in their home (e.g., assisted living facility, school, or clinic).
- Often used when patients visit a local facility equipped with telehealth capabilities.
CMS Definition: According to CMS, POS 2 should be used when the “patient is located in a setting other than their home.”
Examples:
- A patient receives telepsychiatry in a rural clinic.
- A student receives a virtual consult at school.
What is Place of Service Code 10?
POS 10: Telehealth Provided in Patient’s Home
- Introduced by CMS in January 2022 to differentiate telehealth services provided at the patient’s home.
- Important for post-pandemic telehealth trends where patients no longer travel for virtual care.
CMS Guidance:
“Use POS 10 for telehealth services when the beneficiary is located in their home at the time of service.”
Examples:
A follow-up visit for diabetes is conducted via video from home.
A patient receives virtual physical therapy from their living room.
Key Differences Between POS Code 2 and POS Code 10
| Feature | POS 2 | POS 10 |
|---|---|---|
| Patient Location | Not at home | At home |
| Common Settings | Clinics, schools, nursing facilities | Patient’s residence |
| Introduced | Pre-2022 | January 2022 |
| CMS Guidance | Telehealth in non-home settings | Telehealth in home setting |
| Impact on Reimbursement | Slightly lower | Often higher (in some payer policies) |
When to Use POS Code 2 vs. POS Code 10
Use POS Code 2 When:
- Billing private insurers or Medicaid for telehealth services provided in the patient’s home.
- The payer does not specifically require POS Code 10.
- Submitting claims for non-Medicare patients receiving telehealth services at home.
Use POS Code 10 When:
- Billing Medicare for telehealth services provided in the patient’s home.
- The service is provided to a Medicare beneficiary, and the payer requires the use of POS Code 10.
Why the Distinction Matters
Even though both codes are for telehealth, the distinction is vital because:
Policy Compliance: CMS and commercial payers are increasingly focused on ensuring accurate POS usage.
Reimbursement Rates Differ: Some private payers reimburse POS 10 at the non-facility rate, which may be higher than POS 2.
Audit Risks: Using the wrong POS code can trigger denials, audits, or overpayment recoupments.
CMS Billing Guidelines You Should Know
Here are some important CMS points to remember:
- Telehealth Modifier 95: Still required for most telehealth claims.
- POS Code Use:
- Use POS 10 when the patient is physically at home.
- Use POS 2 when the patient is anywhere else.
- Documentation Requirements: You must document the patient’s physical location at the time of service.
- Reimbursement Implications: Some services reimbursed at higher rates when using POS 10 (as it’s considered a non-facility rate by some payers).
Conclusion
Both POS Code 2 and POS Code 10 are used to indicate that telehealth services were provided in the patient’s home. However, the primary difference lies in their payer-specific usage:
- POS Code 2 is used for all payers, including private insurers and Medicaid.
- POS Code 10 is used exclusively for Medicare claims.
Frequently Asked Questions (FAQs)
1. Is POS 10 reimbursed higher than POS 2?
Sometimes. Especially with private insurers who use non-facility payment rates for POS 10.
2. Can I still use POS 2 for home telehealth visits?
CMS prefers POS 10 if the patient is at home. Using POS 2 inappropriately could result in reduced payment or denied claims.
3. Do I need Modifier 95 for POS 10?
Yes. Modifier 95 is still used for synchronous telehealth services.