Business – Page 26

Question Posed Regarding New POS 10

One Person Reaches out to MGMA for Advice:

“I need confirmation regarding the new POS 10. The new POS code 10 and the revision to POS code 02 goes into effect on April 4, 2022 (Medicare), and January 1, 2022, respectively. After the effective date, POS code 10 will be used if a patient receives telehealth at home, and POS code 02 will only be used for the other eligible originating sites (in other words, other places besides a patient’s home where a patient may be located and receive telehealth services that may be reimbursed by Medicare).

It is my understanding that the POS 10 would only be used for mental health/substance abuse telehealth services as they are the only services that will be covered if provided at home.

Should practices continue to use POS 02 until the PHE officially ends or should they begin using POS 10 (January 1, 2022 for all payers except for Medicare) and April 4, 2022 for Medicare? “

Claire Ernst J.D., Government Affairs Director MGMA, Washington DC. Responds:

“Thank you for your question. When I saw CMS’ notice about the revised POS codes in October, I had the same question. My assumption is that POS 10 should be used for the new mental health telehealth services, but most likely once the COVID-19 PHE ends. The mental telehealth expansion provided in the Consolidated Appropriations Act, 2021 (CAA) and subsequently codified in the 2022 final Medicare Physician Fee Schedule (PFS) allows for mental health services to be rendered to patients in their homes (with some conditions). Although this was covered in the 2022 PFS, the mental telehealth expansion provision in the CAA was meant to allow for providers to continue treating patients for mental health conditions from the home following the conclusion of the PHE. Practitioners can continue providing care to patients in their homes through the end of the PHE and will be reimbursed at the in-person rate if the 95 modifier is used.

I reached out to the staff at CMS to confirm, but have not heard back yet. I will follow up with them again and provide any feedback in this thread”