It has been a year since CMS implemented its new place of service coding instructions per CR7631. If you are a Radiation Oncologist providing services in the outpatient department of a hospital and have not reviewed your place of service (POS) coding practices, you could be heading for trouble.

The Office of the Inspector General (OIG) has identified one of the most common POS coding errors is represented by the incorrect use of code 11,“office”, for services provided in the outpatient department of a hospital.

The CMS ruling instructs providers to use the place of service that represents the setting in which the beneficiary received the face-to-face service. Unless a provider has a separately maintained office space in the hospital or medical campus where the services was rendered, the POS is considered “outpatient hospital” and must show POS code 22. 

NOTE: This applies to evaluation and management services as well as “procedural” services.

You may wonder why using POS code 11 instead of 22 makes a difference. For services paid under the MPFS, there is a reduced reimbursement of procedures billed by providers in the outpatient hospital department. This reduction is based upon the facility bearing the costs for the space provided, required support staff and equipment that are utilized in rendering the service.  Expenses the provider is typically responsible for in an “office” setting.

Note: Providers that incorrectly submit POS code 11 are being overpaid for their outpatient hospital procedures, and if audited, are subject to paying refunds to Medicare. This type of “over billing” if determined deliberate would be considered Medicare fraud.                                                           

Avoid overpayments by evaluating the configuration of your practice management system to ensure the POS codes that are being submitted for all of your service locations are set up correctly.

Iridium Suite medical billing software by Medical Business Systems is designed to contain a comprehensive table of all your practice service locations with built-in POS coding tied to each one. This is just one of the many ways in which Iridium Suite enables you and your staff to submit the most accurate and complete billing as possible.