Place of Service Codes, Office of Inspector General's (OIG), POS code, ASCs, Coding, Code, Codes, ambulatory surgery center, Radiology
Place of Service Codes: Get Them Right to Ensure Compliance
April 01, 2011
One of the projects included in the Department of Human Services' Office of Inspector General's (OIG) 2011 work plan is a review of claims for proper place-of-service (POS) coding for physician services. These two-digit POS codes are placed on health care professional claims to indicate the setting in which a service was provided. The Centers for Medicare & Medicaid Services (CMS) maintain POS codes used throughout the health care industry.
The topic of POS codes-mainly the high number of errors on claims--has come up several times recently in literature from CMS, and it seems to be time for physicians and their billers to revisit the policy and ensure compliance with it.
Policy and Problems As you know, Medicare payment to a physician varies depending on where the physician performed the service. Medicare pays a physician a higher amount when a service is performed in a nonfacility setting, such as a physician's office, than it does when the service is performed in a hospital outpatient department or an ambulatory surgery center (ASCs). Incorrect coding of POS can subsequently lead to incorrect reimbursement. Examples of a few commonly used POS codes are listed in the table below.
OIG plans to continue its POS claims review in 2011 because prior studies have found a high incidence of errors. In July, OIG released a report that found that, for 90 of the 100 services in its sample, physicians used nonfacility POS codes on their claims for services that were actually performed in hospital outpatient departments or ASCs. OIG attributes these errors, in part, to lack of internal controls at physician practices.
Compliance Tips To support correct coding, reimbursement managers are encouraged to do the following.
Educate billing staff members on POS distinctions. Hospital outpatient departments and ASCs, except under certain circumstances, do not qualify as nonfacility settings.
Educate billing staff members that an incorrect POS code could affect Medicare reimbursement.
Check for undetected flaws in the design or implementation of billing systems.
Have quality-control measures in place to prevent data-entry errors.
Check with individual payers (e.g., Medicare, Medicaid, other private insurance) for reimbursement policies regarding these codes.
Examples of Commonly Used POS Codes and Descriptions
11 Office Location, other than a hospital, skilled nursing facility (SNF), military treatment facility, community health center, state or local public health clinic, or intermediate care facility, where the health professional routinely provides health examinations, diagnosis, and treatment of illness or injury on an ambulatory basis 21 Inpatient hospital A facility, other than psychiatric, that primarily provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services by, or under, the supervision of physicians to patients admitted for a variety of conditions 24 Ambulatory surgical center A freestanding facility, other than a physician's office, where surgical and diagnostic services are provided on an ambulatory basis 49 Independent clinic A location, not part of a hospital and not described by any other POS code that is organized and operated to provide preventive, diagnostic, therapeutic, rehabilitative, or palliative services to outpatients only
Jeff Majchrzak, BA, RT(R), RCC, CNMT, CIRCC is Vice President of Radiology Services for Medlearn. A nationally renowned radiology coding authority, Jeff has amassed an incredible breadth and depth of experience, both in the healthcare setting and in the field of consulting. His real-world experience includes work in the radiology and nuclear medicine departments of several public and private hospitals. www.medlearn.com