CMS Updates Place of Service Codes for Professional Claims

On August 6, 2015, CMS published an updated “Place of Service Codes for Professional Claims” code set that includes a new Place of Service (“POS”) code for Off-Campus Outpatient Hospital (POS 19) and for On-Campus Outpatient Hospital (POS 22) places of service. Each of the new POS codes will be effective January 1, 2016, and neither of the new codes will have any effect on reimbursement.

The description for POS 19 states: “A portion of an off-campus hospital provider based department which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.” The description for POS 22 now states: “A portion of a hospital’s main campus which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.” POS 22 is presently used to indicate services provided in hospital outpatient departments, irrespective of location.

These updated POS codes follow CMS’s “Final Rule with Comment Period,” released on November 10, 2014 (the “Final Rule”), which included new data collection requirements in an attempt to allow CMS to analyze the frequency, type, and payment of physicians’ and outpatient hospital services furnished in off-campus provider-based departments of hospitals. CMS expects that this information will provide it with a better understanding of how the growing trend toward hospital acquisition of physicians’ offices and subsequent treatment of those locations as off-campus provider based departments of hospitals affects payments under the MPFS and the OPPS, as well as beneficiary cost-sharing obligations.

The updated POS code set is located here.

This News Alert has been prepared for informational purposes only and should not be construed as, and does not constitute, legal advice on any specific matter. For more information, please see the disclaimer.

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