Telehealth Place of Service 02 and 10 Clarification

National Government Services has been receiving inquiries from providers in regard to POS 02 and POS 10 for telehealth service reporting. We’ve created this article to provide clarification.

CMS issued Change Request 13582 (Transmittal 12671) which became effective on 1/1/2024.

Although this transmittal didn’t provide new information, it manualized past instructions and clarified that POS 02 is paid as a facility service, versus POS 10 which is paid at the nonfacility rate. This is identified in CMS Internet-only-Manual (IOM) Publication 100-04, Medicare Claims Processing Manual, Chapter 26, Section 10.5 in the place of service listing.  

Included in this change request and update to the IOM, CMS indicated in “Special Considerations for Telehealth Claims (Code 02, 10)” that the POS may be used and must be paired with the appropriate telehealth modifier (93 for audio-only and modifier 95 for audio/video).  This is new information as the 2024 CMS Physician Fee Schedule Final Rule indicates there are only specific instances for the use of modifier 95. Modifier 93 has not been indicated as necessary for any audio-only services by CMS.  

If you choose to use modifier 93 or 95, keep in mind:

• These are informational modifiers that do not impact the payment or allowance of the service provided and as such should be listed after any payment modifiers.  
• Modifier 93 would not apply to audio only mental health services as CMS has issued specific policy for those services to be billed with modifier FQ.  
• It would not be appropriate to bill FQ and 93.  

Revised 8/12/2024