CMS announces new Place of Service code for telehealth services provided to patients in their homes

CMS has announced a new Place of Service code, POS 10, for use in reporting telehealth services provided to patients who are in their own homes. Additionally, CMS has revised POS 02 for reporting telehealth services provided to patients not located in their own homes.

Place of Service 02 (Revised): 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.

Place of Service 10 (New): 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.

Private payers such as Anthem and United Healthcare may require the reporting of POS 10 for services provided via telecommunication technology to patients who are in their own homes. Visit the Anthem and United Healthcare pages about their telecommunications policy changes for appropriate reporting guidance.

While these codes are effective Jan. 1, 2022 and will be available for Medicare’s use April 1, 2022, Medicare Administrative Contractors are not yet using the new POS codes and dermatologists reporting telehealth services to Medicare should continue to use POS 11, in accordance with the CMS waiver released March 17, 2021, until the end of the COVID-19 Public Health Emergency. (The PHE was recently extended for another 90 days, through April 2022, and the administration has promised to provide 60-days’ notice before allowing the PHE to expire.)

Additionally, dermatologists should be aware that per CMS Change Request 12427 (PDF), Medicare does not require use of telehealth Place of Service codes 02 or 10 during the PHE and telehealth services provided for Medicare beneficiaries should not be denied when reporting these claims with POS 11. Further, Medicare contractors are to instruct their providers to continue to bill according to their telehealth coding guidance during the PHE. Any change of policy regarding use of telehealth POS codes following the end of the PHE would be addressed in subsequent instruction.

The AADA’s practice management coding and advocacy teams continue to monitor Medicare and private payer instructions on reporting POS 10 for telehealth services and will report changes to members via DermWorld Weekly and Derm Coding Consult. For specific reporting instructions, please check directly with the private payers.

Appropriate guidance on reporting of teledermatology services for Medicare beneficiaries during the PHE is available in the Academy’s Practice Management Center.