What place of service (POS) do I use when reading a test from a remote location?

Effective April 1, 2013, Change Request (CR) 7631 establishes that for all services, with two exceptions, paid under the Medicare Physician Fee Schedule (MPFS), the place of service (POS) code to be used by the physician and other supplier will be assigned as the same setting in which the beneficiary received the face-to-face service. Because a face-to-face encounter with a physician/practitioner is required for nearly all services paid under the MPFS and anesthesia services, this rule will apply to the overwhelming majority of MPFS services. In cases where the face-to-face requirement is obviated such as those when a physician/practitioner provides the PC/interpretation of a diagnostic test from a distant site, the POS code assigned by the physician/practitioner will be the setting in which the beneficiary received the technical component of the service.

There are two exceptions to this face-to-face provision/rule in which the physician always uses the POS code where the beneficiary is receiving care as a hospital inpatient or an outpatient of a hospital, regardless of where the beneficiary encounters the face-to-face service. The correct POS code assignment will be for that setting in which the beneficiary is receiving inpatient or outpatient care from a hospital, including the inpatient hospital (POS code 21) or the outpatient hospital (POS code 19 or 22). The Medicare Claims Processing Manual already requires this for physician services (and for certain independent laboratory services) provided to beneficiaries in an inpatient hospital and CR 7631 clarifies this exception and extends it to beneficiaries in an outpatient hospital. 


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