On January 1, 2022, CMS’s Place of Service (POS) Workgroup added new POS code 10, with description Telehealth Provided in Patient’s Home. Simultaneously, the established POS code 02 description was changed to Telehealth Provided Other than in Patient’s Home. CMS Transmittal R11045CP of October 13, 2021, announced these changes and declared they were made to “meet the overall industry needs”. Although in that transmittal Medicare announced that they “[haven’t] identified a need for new POS code 10,” we continue to monitor CMS announcements for further updates prior to their POS 10 April 4 effective date.

According to an American Association of Family Practice (AAFP) blog, the AAFP expects that after the Public Health Emergency (PHE) ends, CMS will revert to their previous geographic/originating site POS requirements for most telehealth services, unless they make a legislative change. Therefore, for traditional Medicare, POS 10 would only apply to tele-mental health services after the PHE.

Changes for Commercial Carriers

As of 1/1/2022, commercial and Medicare Advantage policies of United Healthcare and Anthem began requiring POS 10 on claims submitted for telehealth services provided in patient’s home, and POS 02 on claims submitted for telehealth services provided outside patient’s home.  As of 2/10/2022, other major commercial carriers have yet to define in any detail their expectations regarding use of POS 10.

No payers have yet clarified how telehealth assignment of POS 10 will impact adjudication.  It is possible they will, in time, restrict certain procedures to be performed via telehealth in one or the other (or both) places of service 10 and 02.  Also, it is possible that benefit plans may change to establish different benefit levels for services performed via telehealth. We saw this over 15 years ago as companies such as Teladoc® emerged to provide 24x7 telephone access to physicians.  As payers update their telehealth policies with information on POS 10, we will be monitoring the details so we can adjust our related edits accordingly.