Billing: You Might Report POS 22 More Often Starting in October

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Note:  The following article synopsis was NOT provided by AAPC. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews a CMS place-of-service update affecting physician billing, with special attention to how the reported service location should align with where the patient received the face-to-face encounter. It is relevant to coders, billers, and physician practices that submit claims for services in hospital outpatient departments, inpatient settings, ASCs, and office environments. The article also references CMS transmittals and MLN Matters guidance, along with a related modifier requirement for split professional and technical services.

Why This Topic Matters

Correct place-of-service reporting affects claim compliance and reimbursement. The article highlights a CMS update that practices need to understand in order to avoid incorrect facility-versus-nonfacility billing and related claim submission errors.

Article Sections

  1. CMS place-of-service update

    Overview of a CMS billing update affecting how physicians determine the reported service location. The section introduces the timing of the change and the general concept behind the new guidance.

  2. Diagnostic imaging and interpretation location

    Discussion of how the guidance applies when a patient receives a service in one location and the physician performs a related interpretation elsewhere. The section references CMS clarification materials and a related claims-reporting example.

  3. Exceptions for inpatient and hospital outpatient services

    Summary of special situations covered by the CMS guidance, including inpatient hospital services and hospital outpatient settings. The section explains that certain facility contexts are treated differently from office-based services.

  4. Services performed in ASCs

    Focus on ambulatory surgical center settings and how they are addressed in the revised instructions. The section also notes the relevance of separately maintained office space at the same location.

  5. Related billing compliance considerations

    General reminder about accurate reporting and why CMS is concerned with place-of-service selection. The section also mentions an additional modifier requirement when reporting split professional and technical services.

What You Will Learn

  • How CMS frames place-of-service reporting around the location of a face-to-face service
  • Which general settings are addressed by the guidance
  • What related claim-reporting considerations accompany the update
  • Which CMS resources are cited for further review

Who Should Read This

  • Medical coders
  • Billing staff
  • Physician practices
  • Revenue cycle professionals
  • Compliance teams

Codes Discussed

Modifiers Discussed


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