Whether an urgent care can bill Place of Service -19 or -22 requires an understanding of the criteria enabling facility code sets. An urgent care joint venture between physicians and a hospital recently inquired about using Place of Service 22 (Outpatient Hospital), enabling facility fees.
The key with billing the urgent care as “outpatient hospital” is that it must truly qualify for that service. I have reservations as to whether the urgent care could bill compliantly for facility reimbursement. It would seem best to seek legal counsel with substantial healthcare expertise in order to get an answer as to whether this would qualify for facility coding under POS -22 or POS -19.
The criteria for outpatient hospital services changed as of the first of this year. If the hospital elects to bill this way, the urgent care center should use either POS 22 or POS 19.
- POS -22: On Campus-Outpatient Hospital: A portion of a hospital’s main campus which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.
- POS -19: Off Campus-Outpatient Hospital: A portion of an off-campus hospital provider-based department which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.
In order to bill the facility fees, the hospital should already have criteria for the codes they use. The Centers for Medicare and Medicaid Services does not specify these criteria, but expects them to form a bell-shaped curve. If the hospital has not established these guidelines, they could use and modify the suggestions published by the American College of Emergency Physicians, available at https://www.acep.org/content.aspx?id=30428.
David Stern, MD,
Chief Executive Officer, Practice Velocity, LLC
