April 16, 2020
If the provider is working remotely from home (temporarily), what would the place of service (POS) be?
If billing telehealth visits (with real-time audio and video) then the POS would be the place of service where the provider would have normally seen the patient (office, or hospital-based clinic, etc.) for Medicare and the address on the claim would be the provider’s home address, not the clinic address. Once the provider returns to the clinic he/she can perform telehealth visits and would resume using the clinic address on the claim. That is the CMS requirement for Medicare.
For example, if you would normally have seen the patient in your private practice office then report the E/M code using POS 11. If you would normally have seen the patient in a provider-based clinic in the hospital, then report the E/M code using POS 22.
Don’t forget that Medicare now requires modifier 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) to be appended to all CPT codes reported for telehealth visits.
Commercial payors may or may not follow Medicare guidelines. See Payor Telehealth Policies for more information.
*This response is based on the best information available as of 4/16/20.