POS 10 Telehealth Billing: Modifier Requirements and Common Claim Submission Errors Practices Need to Know
Learn POS 10 telehealth billing requirements, and common claim submission errors that cause denials and delay reimbursement for healthcare practices.
Telehealth services provided in the home setting can use POS 10 code. Properly reporting helps medical practices meet payers’ needs and minimize unnecessary claim mistakes. Note that choosing POS 10 will not ensure coverage and payments. Providers are also responsible for checking eligibility for services, applicable modifiers, documentation, and paying rules for each service. Health planning agencies, however, have the primary concern of maintaining consistency in telehealth claims with evolving reimbursement policies. Ungrouped place of service codes can lead to claims getting denied, payment mismatches, and extra administration. Knowledge of the requirements of the POS 10 can help practices boost claim accuracy and protect revenue.
What Is the POS 10 Code?
POS 10: Telehealth Provided in Patient’s Home. Determines patient location when a covered telehealth service is provided. If this place of service designation is used, the service needs to take place at the same time as billing is made for the service (i.e., must be at the patient’s home). POS 10 became effective on January 1, 2022, on the Centers for Medicare & Medicaid Services (CMS) initiative. Medicare will start accepting the code for claims on April 1, 2022.
POS 10 is not a provider location statement, it is a patient location statement. The physician may provide a telehealth service from their office or other approved site, and may conduct the delivery of the service from there while the patient is at home. Thus, the code does not define reimbursable of a service. Eligibility for coverage is based on coverage policies, service rendered, and provider eligibility, as well as any rules that must be followed for coverage.
When Should Providers Use POS 10?
Place of service 10 is to be utilized when the telehealth rendered is a qualifying service provided to a patient when they are physically located at their place of business. Find out the requirements for the payments coverage and billing of the applicable one.
Typical situations might involve:
- Covered video therapy session with a behavioral health professional in a home setting.
- An eligible virtual follow-up appointment with a doctor.
- A doctor conducts a telemedicine consultation with a patient through a secure telemedicine service.
- A second reimbursable telehealth visit with a qualified health provider with the patient at home.
These examples are not a complete list of services that support this eligibility determination for POS 10 reimbursement. Providers are required to verify if the payer will be paying for the service and any requirements that may apply.
Billing teams should be on the case before submitting a claim by ensuring that they triple check three things:
- Patient setting: Was the patient at home at the time of the visit?
- Service eligibility: If you’re paying for the services, will this be a telehealth service?
- Claim requirements: Do the correct place of service, modifiers and supporting documentation exist?
In cases of telehealth services being received at a site other than the patient’s home, then POS 02 might be more appropriate. POS 12 automatically applies to an in-person service at the patient’s home.
POS 10 vs. POS 02, POS 11, and POS 12
The first step in selecting the right place of service code is to determine the place where the patient received the service. These codes can be mis-interpreted, leading to claims problems and payments.
| POS code | Official description | Typical application |
|---|---|---|
| POS 10 | Telehealth Provided in Patient’s Home | Covered telehealth service when the patient is at home |
| POS 02 | Telehealth Provided Other than in Patient’s Home | Covered telehealth service when the patient is somewhere other than home |
| POS 11 | Office | Professional service delivered in an office setting |
| POS 12 | Home | In-person service delivered at the patient’s home |
POS 10 vs. POS 02
It’s mainly the location of the patient when the telehealth encounter occurs. The patient is at home then Place of service 10 is applied, the patient is receiving telehealth elsewhere then uses POS 02. For instance, when a patient comes in on the virtual visit from their home, they might need Place of service 10. If the patient attends an appointment at the same facility (i.e. workplace) he or she would attend in the home, or at another non-home facility, that patient may need an appointment of the same type as POS 02 (upon the rules of the payer).
The billing staff should not choose the provider only because it provides services remotely. Depending on where the patient is located, one of a number of possible place of service codes may be applicable for telehealth.
POS 10 vs. POS 11
When providing specific services in a work environment, they will be identified in POS 11. Covered Telemedicine Services POS 10 will recognize covered telehealth services when the patient is in their home environment. POS 11 is not necessarily the best fit for a remote encounter, depending on the location where the process will be provided. The billing staff needs to assess the actual service delivery method and patient location.
POS 10 vs. POS 12
POS 12 is used for face-to-face services at the patient’s residence. Place of service 10 applies to qualifying telehealth services if the patient is in their home. This is important because it should not be assumed that a patient’s home address will provide the proper code. The delivery method should also correspond to the service you bill.
POS 10 Reimbursement and Medicare Payment Rules
Correct use of Place of service 10 to achieve reimbursement is just half the battle. The service should also be Medicare compliant to be covered under applicable Medicare policies and billing requirements will need to be met for the claim. Medicare’s Physician Fee Schedule payment treatment for covered professional telehealth services has applied the applicable non-facility payment rate for dates of service on or after Jan. 1, 2024, to services also provided to patients in their home. Practices should ensure the policy in effect on the date the service is delivered is followed as the rules for telehealth may change from day-to-day.
The final amount of the payment may be subject to certain terms:
- Billed with a CPT or HCPCS code: The service must be billed with an accurate representation of the service rendered.
- Date of service: Though coverage and payment rules can vary, it may change over time.
- Professional eligibility: The rendering professional is eligible for the programs pertaining to that.
- Eligible services: Service must meet the relevant telehealth requirements.
- Documentation: A medical record shall adequately justify the reported wording of the claim.
- Patient cost-sharing: Any deductible and coinsurance and other coverage requirements could impact what is collected.
POS 10 does not set a standard reimbursement rate. The Payment will be based on the Service, Payable by the Payer and the Policy applied. If the claim is correctly filled out, a claim may still be denied for other reasons. The billing claims should, therefore, include an analysis of payment deviation where this discrepancy occurs and avoid making presumptions about this deviation as all coming from “pos10”. Bad credit card remittance advice, service code and the amounts noted by the payer in the explanation will be a help in determining the problem.
POS 10 Modifiers and Claim Submission Guidelines
Place of service codes and modifiers convey different information. POS 10 indicates the patient’s location and a modifier can indicate the method of delivery in addition to meeting a reporting requirement established by a particular payer.
Modifier 95 for Synchronous Telehealth
Normally the modifier 95 will be applied when there is a synchronous telehealth service which is audio and video and interactive in real time as required by the applicable Payer’s policy. It doesn’t apply to any and all POS 10 claims, however. Medical claims may need to be submitted with modifiers in a different manner for Medicare, Medicare’s medical plan, and commercial medical plans. Billing teams must get clarity on what the payer’s requirements are for the service and date of service before applying the modifier 95. If the requirements for an application of a modifier are not checked and applied automatically, claim errors can be made.
Audio-Only Telehealth Requirements
Audio-only encounters might have different coverage and reporting requirements than audio-video encounters. Modifier 93 might be applicable in specific situations, as recognized and necessary by the payer. It is important for a billing team to not expect that every call with a customer is eligible for reimbursement. Must be an audio only service as defined by payer and documentation should substantiate service.
FQHC and RHC Considerations
FQHCs and Rural Health Clinics (RHCs) may have unique telehealth billing requirements. These may be claim format, modifiers or specific claim payment rules for specific types of claims. Such as billing contexts involving an FQHC or RHC could qualify for modifier FQ. Uses are determined by the information provided in the instructions and the services offered. The healthcare administrator should check current Medicare guidance and specific requirements of the payers before submitting a claim.
POS 10 Claim Review Before Submission
A structured claim review can provide a resource to spot the same claim that will help to prevent errors from getting to the payer.
| Review item | What billing staff should confirm |
|---|---|
| Patient location | The patient was at home during the encounter |
| Service code | The CPT or HCPCS code matches the service provided |
| Place of service | Place of service 10 matches the documented location and delivery method |
| Modifier | Required modifiers follow the payer’s current instructions |
| Documentation | The record supports the billed service |
| Authorization | Any required authorization or referral is documented |
| Payer policy | The service meets the applicable coverage requirements |
These should be performed as part of the regular claim flow. They should not be a routine administrative procedure that is used to stall normally completed claims.
Common POS 10 Billing Errors That Affect Revenue
A claim may be denied, incurred a payment adjustment, or require time to correct due to incorrect reporting at the POS. The financial impact will vary by circumstances of the claim, financial condition of the enrollee and, of course, the error itself and the payer policy.
1. Reporting the Wrong Patient Location
Patients can be transported to the appointment with a non-home origin (POS 10) while making a claim. The reverse is possible if the patient was at home and sent a POS 02. Errors typically are caused by billing employees assuming default values for the information for which they are billing, but they do not always come from that type of source. Documenting patient location repeatedly minimizes unnecessary differences.
2. Applying Modifiers Without Checking Payer Rules
Some billing departments append modifier 95 on all telehealth codes. Others omit required modifiers because they assume POS 10 communicates all necessary information. Either way can be a problem. The modifier is the one that is determined by the services rendered and the method of delivery, the payor and also the instructions.
3. Billing Services That Do Not Qualify
It is impossible for a place of service to render a service that is not otherwise payable. Coverage may be subject to the code, type of provider, telehealth methodology, and rules in effect on the date of the receipt of the service. Billing staff needs to verify that the service is eligible for billing prior to submission. This is especially crucial in the event that policy changes or payers may require different requirements.
4. Missing Documentation or Authorization
If a medical record doesn’t meet the requirements for the billed encounter, it can create audit and reimbursement risks. The consequence of missing the authorization might also impact payment if the payer wants authorization. Codes should be supported by documentation that fully depicts the services provided. If it is found that a bill is for some reason unlawful, staff should check their authorization needs first.
5. Overlooking Payer-Specific Requirements
Medicare regulations shouldn’t automatically extend to Medicaid or commercial insurance claims. Telehealth policies and modifiers required, as well as reimbursement conditions, may vary among state Medicaid programs and private insurers. Collating all payers into a single stream of work can result in mistakes being repeated. Billing teams must have a straightforward way of validating instructions from payers.
6. Failing to Review Denial Trends
If this is an isolated issue, it shouldn’t cause too much concern; however, if the problem occurs regularly it could be a larger workflow issue. For instance, if the length of time that has elapsed since the last POS 10 denial is simply too long, it may indicate out-of-date payer guidance, not enough staff training, or improper defaults. Examine denial codes and remittance advice to determine what is causing it. Fix the process that caused the errors so that you don’t constantly have to correct claims, one by one.
POS 10 Rules for Medicaid and Commercial Insurance
There may be variations for Medicaid programs and commercial health plans in the requirements for reporting for each individual Place of service 10. Medicare doesn’t always get the same billing and payment procedures from other payers.
Medicaid Telehealth Billing
State policies set Medicaid telehealth coverage and reimbursement policies under federal guidelines. States can set other coverage criteria, provider criteria, coverage documentation criteria and coverage payment procedures. Billing personnel should take time to familiarize themselves with state Medicaid guidelines and plan managed care policies. Ensure that the service and provider, mode of delivery, and place of service is adequate to satisfy applicable requirements.
Commercial Insurance Telehealth Billing
Commercial insurance companies may have their own policies in place under existing policies and legal mandates that comply with the requirements of applicable laws and contractual provisions. The rules they have vary from one another, with respect to covered services, eligible providers, modifiers and reimbursement. A practice should keep the guidance of its dominant payers up-to-date. Staff should check new changes to the policy and not assume policy outcomes from the past.
Building a Payer-Specific Reference
A short payer reference can assist with billing staff correctly applying the proper requirements. Should include staff information to be used when preparing a claim.
Include:
- Covers telehealth services and restrictions.
- The following will cover the POS 10 and POS 02 reporting instructions.
- Modifiers that must be applied to the appropriate service types.
- Authorization & documentation.
- Details on contact with patients about payment or review of policy.
- Clarification of requirements by internal procedures.
Make the Director responsible for keeping this reference updated when there are changes in the medical coverage policies of the payers. This limits the reliance on informal knowledge, no-cost billing.
How Medical Billing Teams Improve POS 10 Claim Accuracy
To ensure reliable telehealth billing, it is crucial to have accurate encounter information, up-to-date payer rules, and consistent claim review. Using POS 10 checks in revenue cycle management workflows can help enhance these aspects of patient satisfaction.
Verify Encounter Information Before Billing
Use the encounter record to reconfirm with the patient’s location and method of service. Make sure the documented information is supportive of the selected place of service code. Staff need to settle on a difference in information before the claim is submitted if it doesn’t exist. If the sitter is unable to determine where the patient is, this can bring about preventable billing and compliance issues.
Maintain Current Payer Rules
Set up Medicare, Medicaid and Commercial Payers update process. There should be rules within the training that will seek to influence the claim level of the organization. Alternatively, it could be useful to devote more attention to particular training instead of repeating general definitions of telehealth.
Monitor Denials and Payment Variances
Track denied telehealth services by payers, service, modifier and reason. This enables teams to differentiate between errors of POS, authorization, eligibility, and documentation. Discuss variations on recurring payments with remittance advice. Before changing a policy or billing process, if a pattern emerges, examine a policy and workflow that gave rise to it.
Establish Clear Ownership
Determine who is reviewing encounter information, who will be managing payer instructions and who will be handling denied claims. If it is established what each particular department does, then it is far less likely that any errors will be passed from department to department. Periodic mirroring will determine the settings that should be changed and training needs. Practice leaders can also gain insight into operational considerations that support revenue leakage from telehealth from these reviews.
How Billing Care Solutions Supports Accurate Telehealth Billing
Billing Care Solutions is a team that helps medical service providers to manage medical billing and revenue cycle tasks. Selecting a POS 10 is just the start to getting telehealth claims correctly coded. Team members will need to coordinate the following: encounter info, coding, payer requirements and claim follow up.
Support can include:
- Claim Review: Ensuring consistency of place of service codes and other claim details.
- Payer requirement verification: Review of the applicable billing instructions for covered telehealth services (payer requirement verification).
- Denial Management: Exploring Rejection/denial reasons and supporting claim corrections as appropriate.
- Accounts receivable follow-up: Checks to ensure claims are followed up and prioritized upon claims status.
- Revenue Cycle Reporting: Fact-finding exercises around recurring billing problems and potentially implementing workflow changes and training for staff.
The processes contribute to the resolution of claim errors that are preventable, and improve billing monitoring within practices. The results will depend on the policies of the payers, nature and complexity of claims, details of claims documentation and workflows. Addressing waste and rework from practices with large numbers of telehealth claims during a consistent review process. It also may enable a leader to detect trends that can start a larger number of claims if he is in a position to identify the problem early.
Conclusion
POS 10: covered telehealth services during the patient’s home. Accurate encounter information and right coding and adherence to the payer-specific billing requirements are essential to correct reporting. Healthcare organizations aren’t looking to randomly pick a code they want one to make sense. It is intended to create a repeatable system to eliminate unnecessary mistakes, ensure proper reimbursement and enable identification of “coming and going” claim issues.
Accurate documentation, up to date payer guidance and regular denial monitoring, can help improve claim management for telehealth. Having a defined revenue cycle process also chips away at payment problems without the need for multiple manual corrections.
