Information in this article was updated July 2023, based on the 2024 Proposed Physician Fee Schedule Rule.
Coding telehealth visits changes faster than the weather here in New England. The resources on the site relate to Medicare policy and CPT codes and rules. Unfortunately, they don’t address individual commercial payer policies.
- There are two new POS codes for coding telehealth visits, but don’t start using them for Medicare.
- Place of service codes determine if the encounter is paid at the facility or non-facility rate. The non-facility rate is a higher rate of reimbursemnet.
- Congress passed a law 12/20/2020 that allows behavioral health services to continue to be billed via telehealth after the end of the public health emergency.
- The Consolidated Appropriates Act, 2023 extended certain telehealth flexibilities through Dec. 31, 2024. These are described in another article on CodingIntel.
CMS is proposing that beginning in CY 024, claims submitted with POS 10 will be paid at the higher, non-facility rate.
Beginning January 1, 2024, claims submitted with POS 02 will be pad at the lower, facility rate.
POS 02: Telehealth Provided Other than in Patient’s Home
Description: 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. (Effective January 1, 2017) (Description change effective January 1, 2022, and applicable for Medicare April 1, 2022.)
POS 10: Telehealth Provided in Patient’s Home
Description: 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. (This code is effective January 1, 2022, and available to Medicare April 1, 2022.)
See CMS’s MedLearn Matters article describing the new POS code. It seems to indicate we shouldn’t use it! Here is what they say:
“Medicare hasn’t identified a need for new POS code 10. Our MACs will instruct their providers to continue to use the Medicare billing instructions for Telehealth claims in Pub. 100-04, Medicare Claims Processing Manual, Chapter 12, Section 190.”
This policy is confirmed in the 2023 Physician Fee Schedule Final Rule.
“As such, we are finalizing that we will continue to allow for payment be made for Medicare telehealth services at the place of service for telehealth services that ordinarily would have been paid under the PFS, if the services were furnished in-person, through the latter of the end of the of CY 2023 or the end of the calendar year in which the PHE ends. For those services furnished in a facility as an originating site, POS 02 may be used, and the corresponding facility fee can be billed, per pre-PHE policy, beginning the 152nd day after the end of the PHE.” page 197
Continue to use the place of service in which the service would have been provided until Dec. 31, 2023. CMS has extended this policy, which allows services that would have been performed in the office to be paid at the non-facility (higher) rate until Dec. 31, 2023.
One MAC, NGS posted a question about this, which is linked below.
And, here is a link to the Family Practice Management journal article that describes the policies of two other payers.
Coding telehealth visits
- Telemedicine and COVID-19 FAQ
- Telemedicine in RHCs and FQHCs
- Is it or isn’t it a telehealth service
- Telemedicine | Webinar
- Payment for telephone calls
- Overview of Medicare telehealth services
- Interprofessional Internet Consultations
- CPT® codes (99421-99423) – and payment for – online digital evaluation and management (E/M) services
- Virtual communication: two new HCPCS codes G2010 and G2012
- Should we begin using the new CPT modifier -93
- Modifier 95
- Modifier CS
- Medicare changes telehealth rules, again
Telehealth source documents you can download
- CMS list of telehealth
- AMA coding advice
- CMS interim rule – March 30, 2020
- CMS interim rule – April 30, 2020
- CMS enrollment COVID-19PEHotline
- Aledade guide to getting started with telehealth