July 25, 2014

Centers for Medicare and Medicaid (“CMS”) CR7631: Changes to Place of Service Coding Effective April 1, 2013

After the OIG identified a high error rate for Place of Service (“POS”) modifiers over several years, the Centers for Medicare and Medicaid (“CMS”) issued a billing and coding revision (CR 7631) to instruct any physician, provider or supplier billing Medicare contractors for services paid for under the Medicare Physician Fee Schedule (“MPFS”) on the proper use of POS modifiers for the professional component or the technical component of diagnostic tests. 

CR7631 establishes that for all Medicare payable services – with two exceptions – physicians, providers and suppliers must assign the POS modifier that corresponds with the setting where the patient received face-to-face healthcare services. For example, if a patient has an x-ray taken at an urgent care facility and the interpreting radiologist reads the x-ray film in their office, the appropriate POS modifier for both the professional component and technical component of such x-ray is POS modifier 20. Thus, the interpreting radiologist must use POS modifier 20 even though he/she read the x-ray in a medical office. 

The two exceptions to the “face-to-face” rule apply when the patient receiving care is an inpatient or an outpatient of a hospital. In these two instances, physicians, suppliers and providers must use the POS modifier that is consistent with the patient's inpatient (POS modifier 21) or outpatient hospital status (POS modifier 22). 

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About the Author


Stacey A. Borowicz is a member of the Corporate Department. Stacey counsels healthcare clients on business transactions, formations, mergers, acquisitions and employment-related transactions. Her experience includes handling matters involving fraud and abuse, Stark, anti-kickback and false claims. Stacey drafts compliance plans and performs antitrust, fraud and abuse, anti-self referral law, Medicare coding and billing compliance, HIPAA, and corporate compliance analyses. She regularly represents physician practices, ambulatory surgery centers, imaging centers and other physician-...


About the Author


Simi Botic is a member of the Litigation Department and Business & Fiduciary Litigation Practice Group.

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