clinical social work association

April 27, 2022

I have received a deluge of emails from you about the use of POS “10” for Medicare and other insurers. This guidance that Medicare has provided about this policy is complicated.

The current guidance from CMS is that:

• POS “11” should be used until the end of the Public Health Emergency, timing of which is currently unknown, even though this is not what the POS “11” is for.
• And, as of April 4, 2022, there is some variation according to Medicare Administrative Contractors (MACs) about whether or not to move to POS “10” as initially stated by CMS.
• Check with YOUR MAC to clarify which POS code is being accepted currently if the patient is being seen through telemental health in their home; for example, technically, if a patient is in their car, the POS code should be “02”.
• You can find your MAC contact information at the CSWA website under “Clinical Practice”.
• The Medicare Modifier for POS codes is still 95. This may seem counterintuitive as 95 is supposed to be for telemental health but it is the only combination that currently works.

Be sure to check with EACH private insurer for a patient to find out what combination of POS and Modifier are being requested so that claims will not be denied.

I hope this resolves the confusion about POS codes. Let me know if there are any other questions.

- Laura Groshong, LICSW, CSWA Director of Policy and Practice