CMS Guidance on Place of Service (POS) Coding PROFESSIONAL AND TECHNICAL COMPONENT GUIDANCE By Missy Lovell he Centers for Medicare and Medicaid Services (CMS) published Transmittal 2407, entitled “Revised and Clarified Place of Service (POS) Coding Instructions,” in February of 2012 with an (at the time) effective date of April 1, 2012. There were many awaiting the February 2012 issuance, as in 2009, CMS attempted to clarify the POS instructions for the professional (PC) and technical components (TC) of diagnostic tests and later rescinded that clarification in anticipation of future guidance. time passed, and the february 2012 guidance came somewhat unexpectedly for some. it has since evolved through revisions and delays, and providers faced an april 1, 2013 effective date to implement the Pos instructions as noted in the current transmittal 2613. the instructions essentially revised and added sections to various chapters of the medicare claims Processing manual, including: • chapter 12 and the site of service payment differential; • chapter 13, in which a new section addresses Pos instructions for the Pc and the tc of diagnostic tests; and • chapter 26, which involves special “consideration provisions” for application of Pos to mobile units, walk-in retail clinics, and others. the amount of revised and added materials is large, and this article highlights some of the more significant impacts that the new guidance might hold for various providers. some may feel minimal or no impact while others will continue to struggle to accommodate the guidance. in a march 29, 2012 Pos transmittal that was eventually rescinded and replaced, cms: • explained that it was attempting to input and clarify within the instructions when entities may bill for a global diagnostic code; • Provided the appropriate address to report for determining the payment locality assignments of global service codes and professional interpretive service codes; and very importantly • stated that “clarification on the Pos for pathology services will be provided through another change request (cr).” as of the writing of this article in early march, that pathology clarification has yet to be published, but the vast amount of newly revised materials has left many struggling to accommodate the updated clarifications. there were two very important aspects to the newly issued guidance: correct designation of the Pos code and a clarification of the designation of the service location as it pertained to global and Pc billing of diagnostic services. the pathology-specific guidance issued in the future will be assumedly very similar to the current guidance with clarification on issues unique to their provision of services. one of the drivers of the newly issued guidance is stressed in the transmittal itself as “the importance of this national policy is underscored by consistent findings, in annual and/or biennial reports from calendar year (cy) 2002 through cy 2007, by the office of the inspector general (oig) that physicians and other suppliers frequently incorrectly report the Pos in which they furnish services.” they cite oig findings that show that a significant percent of sampled claims incorrectly reported the Pos, and in many cases found that the non-facility rate may have been incorrectly paid. the Pos designation instruction is clear and now clarified. for all services paid under the medicare Physician fee schedule (mPfs), the Pos code to be used by physicians and other suppliers shall be assigned as the same setting in which the beneficiary received the face-to-face service, with minimal exceptions. the “face-to-face” Pos designation guidance should, as they note, cover the majority of services billed to cms, but they provide distinction of that guidance when there are instances where a face-to-face encounter does not occur (specifically when a physician or practitioner provides the Pc or interpretation of a diagnostic test from a distant site). in those cases, cms instructs providers to assign the Pos of the setting in which the beneficiary received the technical service. in addition to the above, it also mandates that the provider T 42 hbma billing • may. june.2013
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