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New POS Code for Telehealth Distant Site Providers [Ober|Kaler]

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A new Place of Services or POS code for Telehealth services (POS 02) will go into effect on January 1, 2017. The descriptor for the code, which is for use by the physician or other clinician furnishing telehealth services from a distant site, is as follows, “The location where health services and health related services are provided or received, through telecommunication technology.” MLN Matters MM9726 [PDF]. Use of the new code does not impact the requirement for GT or GQ modifiers; they are still required. Claims for telehealth billed without the new POS and the applicable GT or GQ modifier will be denied. The code does not apply to the billing originating site, i.e., the site where the patient is located, and, in effect, CMS will not have information as to the patient’s location or any details regarding the originating site. Potentially this focus on the distant site provider v. the originating site could forecast more flexibility within Medicare’s policies as to what sites may qualify as originating sites. Only time will tell. 

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