POS 61

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Fri Oct 03, 2014 8:46 am

What E/M codes should be reported if a patient is in an Inpatient Rehab Facility or IRF and comes to an ortho’s office for an office visit? Would we report subsequent inpatient hospital day codes (99231-99233) with POS 61? Also, for the technical component on the x-rays would we bill Medicare or bill the IRF?
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Thu Oct 09, 2014 3:09 pm

Thank you for your inquiry, it has been sent on to our certified auditors and once we receive a response it will be posted here.
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Tue Oct 14, 2014 3:06 pm

Answer provided by NAMAS Team members: John Burns and Shannon DeConda;


If a patient is presenting to an orthopedic office, the place of service would be 11 and the CPT codes reported would be new patient or established patient codes 99201-99205. If a particular pair still recognizes and pays for consultations, those codes could also be considered (99241-99245).

So IP Rehab is place of service 61, but that is NOT where you saw the patient and therefore filing that place of service could be construed as a false claim. You saw the patient at your office and therefore the POS is 11.
Now, here is the problem- when a patient is IP Rehab- ONLY the professional services the physician performs are reimbursed. Therefore the technical portion of the xray would be non-reimbursed by Medicare.
Technically, this portion should be paid by the IP Rehab through their daily per diem rate- and I’m sorry to say to you this way- but good luck collecting it! I would treat this as a learning experience and suggest getting some sort of contractual relationship in place for future services to guarantee reimbursement.
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Wed Jan 28, 2015 11:53 am

My comment is on the same subject, just a different POS. We have had several claims denied when using the "correct" POS of 11, for services provided in our office, for a patient who is a registered inpatient of a nursing home. We are being instructed to file a "corrected claim, with POS 31" in order to have our claim paid. I agree that this would be a false claim, as the services were provided in our office...
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Tue Feb 03, 2015 11:47 am

This is becoming a more common problem we are hearing about.
The problem is that when the patient is in the SNF they are designated as IP, but the SNF Guidelines do indicate that Physician services are billable in addition to- however this would represent E&M services. Ancillaries and testing are still subject to the SNF per diem payment from Medicare directly to the SNF and therefore your practice should have an established contract direct with the nursing home to bill for those services directly to them- this is why changing the POS to 31 would get the service paid-- you would still NOT get paid for the TC portion of x-rays and applicable TC/PC services, but rather ONLY the -26 physician service.
On the Medicare website, the following is a direct cut/paste:
•Physicians' services furnished to SNF residents:
These services are not subject to CB (consolidated billing) and, thus, are still billed separately to the Part B carrier. Many physician services include both a professional and a
technical component, and the technical component is subject to CB. The technical component of physician services must be billed to and reimbursed by the SNF.

Consolidated billing simply defined is a requirement that a SNF itself must submit all Medicare claims for the services that its residents receive.

Here is a link to the CMS website for more information:
http://www.cms.gov/Medicare/Medicare-Fe ... lling.html
Thank you,
Founder & President of NAMAS

Disclaimer: NAMAS cannot be held liable for any advice given that could have had a variable answer based on additional information.
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