Place of Service Clarification

Physicians and billers have long struggled with using place of service “inpatient hospital (21)” for patients brought to their office from the hospital for a visit. A CMS transmittal with an implementation date of April 2, 2012 provides clarification on place of service (POS) coding.

It states:

Special Considerations for Inpatient Hospital (Code 21)

In the case of a physician/practitioner/supplier who provides services to a patient who is an inpatient of a hospital, the inpatient hospital POS code 21 will be used irrespective of the setting where the patient actually receives the face-to-face encounter.

The Office of Inspector General (OIG) consistently found that physicians were incorrectly reporting POS office (11) for these encounters when it should have been POS inpatient hospital. Recovery Audit Contractors (RACs) have found numerous instances of overpayments on this specific issue as well.

For a complete review of the MLN Matters article on this topic, visit the CMS website at:

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