Billing & Compliance | About a 5 minute read
If you see clients by telehealth, there are two little numbers on every claim you send that most of us never think about: the place of service code. For telehealth it is almost always either 02 or 10, and a lot of EHRs quietly pick one for you and never ask again.
That used to be a pretty harmless shortcut. These days it can affect how much you get paid, and the habit underneath it (not asking where your client is) can affect a lot more than your claims. So let’s walk through it together, without the jargon headache.
POS 10 means telehealth provided in the patient’s home. Medicare describes home as a private residence, as opposed to a hospital or other facility.
POS 02 means telehealth provided somewhere other than the patient’s home. A lot of people think of 02 as the “facility” code (and that instinct isn’t wrong, which we’ll get to in a second), but technically it covers anywhere the client isn’t at home. That could be a clinic, but it could also be their office at work or a friend’s house.
So the question isn’t “was this telehealth?” The question is “where was my client sitting when we met?”
When telehealth first got going, the typical setup was a patient sitting in a clinic or hospital (called the originating site) connecting with a provider somewhere else. That facility billed its own fee for hosting the visit, so the provider was paid the lower facility rate. POS 02 grew out of that world, and it still carries that logic.
Starting in 2024, Medicare made the split official. Telehealth to a client at home (POS 10) is paid at the non-facility rate, which is the full rate you’d expect for an office visit. POS 02 is paid at the lower facility rate. Some commercial payers are moving in the same direction, so it’s worth checking each payer’s current telehealth policy and keeping an eye on your remits.
Bottom line: if your client was at home and your claim says 02, you may be getting paid less than you should for the exact same session.
This one comes up all the time, and for good reason. Plenty of clients step out to the car in the driveway because the house is full of kids, partners, or roommates and they want some privacy (honestly, who could blame them).
Medicare has addressed this directly for mental health telehealth. If a client goes a short distance from home for privacy or other personal reasons, the session is still considered furnished in the home. Medicare has also said temporary lodging, like a hotel or a shelter, can count as home. So the client in the car in their own driveway is generally still POS 10.
Commercial payers usually follow the same place of service definitions, but not every payer has spelled out the “short distance from home” piece in writing. If a situation feels gray, document what happened and check that payer’s policy.
Most practices don’t ask, and most practices don’t change the code. I get it! It feels like one more thing in a session that already has a lot going on. But there are two separate risks here, and the bigger one isn’t about billing at all.
1. Your license and your client’s safety. You can only provide services to clients who are physically located in a state where you hold a license at the time of the session. If a client is on vacation two states away and you don’t know it, the problem isn’t a coding error. It’s practicing outside your license. You also need to know where your client is if something happens in session and you need to send help. Most licensing boards and professional ethics codes expect you to confirm location for telehealth sessions for exactly these reasons.
2. Billing accuracy. The place of service code is supposed to reflect where the client actually was. If you bill 10 every single time and a client was really at work, that claim is technically wrong in the direction that pays you more. One honest mistake isn’t the end of the world. The bigger issue shows up in an audit. If your notes never document where the client was, the payer has nothing to verify your code against, and some payers will recoup the difference across a whole sample of claims rather than just one.
Ask every time. Start each telehealth session with “Where are you joining from today?” Most clinicians fold it into their check-in so naturally that clients stop noticing.
Document it. Add one line to your note, something like “Client confirmed location: home, Mooresville, NC.” If your EHR lets you build it into your telehealth note template, even better.
Set a smart default. Keep POS 10 as your default for telehealth and only switch to 02 when your note says the client was somewhere other than home.
Check your modifiers. For a live video session, many commercial payers want modifier 95 along with POS 10. Confirm what each of your payers requires, since this varies.
Spot check your remits. Pull a few recent ERAs for telehealth sessions and compare what you were paid on 02 versus 10 claims. If the numbers look off, that’s your sign to dig in.
That one question gives you a single documented answer that covers your license, your client’s safety, and your claims, all at once. Not bad for five seconds.
If you’re not sure how your EHR is set up for telehealth, or you’d like someone to look over your recent claims and remits, that’s exactly the kind of thing I help with at Candor Collective. You can book a free 15-minute intro call at candorcollective.org, and we’ll figure out what makes sense for your practice.
This post is general billing and compliance information, not legal advice. Payer policies change often, so always confirm current requirements with each payer. If you’re worried about a pattern across past claims, a healthcare attorney is the right person to talk to.