New Place of Service Code 10 for Telehealth

Effective January 1, 2022 a new Place of Service Code 10 for telehealth is available. As explained by CMS, POS Code 02 will only be used for telehealth if the patient is not located in their home during the telehealth session.

POS 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.

POS 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.

FOR MOST OF OUR CLIENTS, THE NEW POS CODE 10 WILL APPLY. However, very few payers so far have implemented this change.

To our knowledge, Anthem Blue Cross Blue Shield and United Healthcare are requiring the new POS Code 10 if the patient is seen in their home. If providers are aware of any other payers requiring this new code, please let us know.

For Medicare during the COVID-19 Public Health Emergency (PHE), traditional Medicare will continue to require physicians to bill using the POS they would have used if the service had been provided in person. After the PHE, unless there’s a legislative change, CMS will revert to the geographic/originating site requirements for most telehealth services. Therefore, for traditional Medicare, POS 10 would only apply to tele-mental health services after the PHE. Per the CMS bulletin, the new POS code won’t be implemented under traditional Medicare until April 4, 2022, at the earliest.

What does this mean for Medicare? Some providers have mistakenly been using POS code 02 for telehealth for Medicare...But if you normally would see patients in your office (POS code 11) you should continue to use POS Code 11 for telehealth for Medicare patients (do not use 02). And providers should not use the new POS Code 10 yet for Medicare.

• For our TherapyNotes Users, you should set up a new Practice Location for Telehealth (call it Telehealth-10) that you will use for Anthem BC BS, United Healthcare and any other payers that will require this POS Code.
  • If you want us to set up the new location for you in TherapyNotes, just let us know.
• For our non-TherapyNotes users, please continue to report telehealth on our billing log the way you have all along. We will use the POS Code 10 for those payers that require it now, we will use 11 as we have been for Medicare, and we will use 02 as the POS Code for all other payers (unless that payer wants a different code).

Thanks,

Steve