POS Coding Under Scrutiny

Centers for Medicare and Medicaid Services (CMS) along with other commercial payers have started aggressively auditing practices for incorrect Place of Service (POS) codes.   This was based on the Office of Inspector General’s (OIG’s) review of non-facility (office) services provided which were matched to hospital outpatient or ambulatory  surgery center (ASC) claims for the same date of service. 

Services that were billed in an office setting but were actually provided in a hospital outpatient or ASC resulted in an overpayment of $13.8 million from 2007.   The OIG has recommended that CMS reopen all claims in this category and recover overpayments.

It is critical that all practices are utilizing the correct POS code.    POS codes are as follows:

Office (11) – location where physician(s) incur all of overhead costs

Outpatient Hospital (22) – Services provided in space that is hospital-owned and operated by the hospital.  There are no overhead costs for the physician.
Surgery Center (24) – Any service performed in a Medicare-certified CMS   

Maureen Doherty is a Health Care Services Group Consultant providing coding, billing and insurance claims processing services to a variety of multi-specialty practices.

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