Place of Service (POS) 10 in medical billing is one of the most important billing codes in modern healthcare. As telehealth becomes a permanent part of how patients receive care, getting this code right can directly impact your reimbursement, compliance standing, and claim approval rates.
This guide covers everything you need to know about what POS 10 means, how it works, when to use it, and how to avoid the most costly billing mistakes.
What Is POS 10 in Medical Billing?
The Centers for Medicare & Medicaid Services (CMS) defines place of service code 10 as the location where health services are provided through telecommunication technology while the patient is in their home.
Put simply: telehealth + patient at home = POS 10.
In medical billing, a place of Service code is a two-digit code used on professional claims to show the setting where care happened. These codes tell payers exactly where a service was delivered, and that location directly affects how much a provider gets paid.
POS 10 became effective in the national POS code set on January 1, 2022, and CMS says it became available to Medicare on April 1, 2022. Any billing guidance from before that date is now outdated, so make sure your team is working from the current CMS documentation.
Why POS 10 Exists
The rise of telehealth during the COVID-19 pandemic created a need for more precise billing codes. Since the COVID-19 outbreak, telehealth has emerged as a cornerstone of healthcare delivery, enabling patients to access care from the comfort and safety of their homes. Recognizing the rapid shift in healthcare dynamics, CMS acted swiftly to address the billing complexities of this new normal.
Place of service 10 code became mandatory for many telehealth claims after CMS updates in 2022, and as of 2025, it remains a key compliance requirement for Medicare, Medicaid, and most commercial insurers.
The expansion of telehealth services accelerated by the COVID-19 pandemic has led to a permanent shift in how care is delivered. POS 10 is now central to how the billing world categorizes and processes these encounters accurately.
Where Is POS 10 Used? The CMS-1500 Form
POS 10 is used on professional claims. Specifically, it belongs in Box 24B of the CMS-1500 claim form, which is the standard claim form used by physicians, outpatient clinics, and non-institutional providers.
CMS Place of Service Codes are mandatory on CMS-1500 forms. They help payers determine if the claim matches the procedure and the service location.
The UB-04 form, used by hospitals and institutional facilities, does not use these POS codes. If your practice submits professional claims for telehealth services delivered to patients at home, POS 10 is the code that belongs in that box.
What Qualifies as “Home” for POS 10?
The definition of “home” is broader than just a permanent private residence. The term “home” is defined as the location where the patient resides, which can include a private residence, temporary lodging, or another non-facility living arrangement.
However, there are clear boundaries. POS 10 indicates the patient is located in their home when receiving health services or health-related services through telehealth. Home is defined as a location where the patient receives care in a private residence. It does not include hospital or other facility settings.
If the patient happens to be at a clinic, hospital, skilled nursing facility, or any institutional setting during the telehealth call, POS 10 is not the correct code. The key question is always: Where is the patient physically located at the time of service?
POS 10 vs POS 02: What’s the Difference?
It is the most commonly confused pairing in telehealth billing, and the distinction is simple once you understand it.
- 10 POS signals to payers that the patient was at home, which qualifies for non-facility rates. It ensures higher reimbursement for providers while accurately documenting the residential setting of telehealth encounters.
- POS 02 signals to payers that the service occurred outside the patient’s residence. It guides payment processing, ensures correct claim classification, and differentiates telehealth from in-person facility visits in audit reviews.
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The Financial Impact: Why POS 10 Pays More
One of the biggest reasons accurate POS 10 coding matters is money. The reimbursement difference between the two telehealth POS codes is significant.
Claims submitted using POS code 10 will be reimbursed at the non-facility rate according to the Medicare Physician Fee Schedule. The average non-facility rate for telehealth services is approximately $92, compared to an average of $58 for services provided in a facility setting.
Starting January 1, 2024, the Physician Fee Schedule (PFS) introduced a significant update: telehealth services billed with POS 10 are now reimbursed at the non-facility rate, which is higher than the facility rate. It marks a departure from previous reimbursement policies, where telehealth services at home often received lower rates.
That difference, roughly $34 per claim on average, adds up fast for any practice with high telehealth volume. Using POS 02 when POS 10 is correct means systematically underbilling, losing revenue on every single home-based encounter.
Required Telehealth Modifiers to Pair with POS 10
A POS code alone does not complete a telehealth claim. Every telehealth claim must also include a modifier that describes how the service was delivered. Here are the three modifiers most commonly paired with POS 10:
Modifier 95 (Synchronous Audio/Video)
Modifier 95 is used for synchronous (real-time) audio-video telehealth. It is the standard, most common modifier for POS 10.
If your provider and patient are connected via a secure video platform in real time, Modifier 95 is what you need. It is the default for most routine telehealth visits.
Modifier 93 (Audio-Only)
Modifier 93 is used specifically for approved audio-only telehealth when the patient is at home and meets the exception criteria.
For audio-only claims with Modifier 93, you must record that the audio-video was available but not used, and state the reason (e.g., no device, poor internet, patient declined). For mental and behavioral health, audio-only is permanently permitted, but patient consent must be documented.
Modifier FQ (Audio-Only for FQHCs/RHCs)
Modifier FQ is used by Federally Qualified Health Centers and Rural Health Clinics when billing audio-only services.
Which CPT Codes to Use with POS 10
It is an area where many billers make costly mistakes. Telehealth visits from the home should continue to be billed using in-person E/M CPT codes (99202–99215). Do not use the CPT telemedicine code range (98000–98015).
That means you use the same E/M codes you would for an in-person office visit. The POS code and modifier are what differentiate it as a telehealth service. Using the newer 98000–98015 range for Medicare home-based visits is a coding error that will result in claim denial.
As of 2024, over 200 telehealth services are covered under Medicare, including evaluations, therapy sessions, and certain diagnostic tests.
Documentation Requirements for POS 10 Claims
Solid documentation is your most important protection against denials and audits. Post-visit documentation must be as thorough as possible to ensure prompt reimbursement. There are many similarities between documenting in-person visits and telehealth visits.
Your notes must clearly include:
- Date and time of the telehealth encounter
- Patient’s location explicitly confirming the patient was at home
- Communication method used (e.g., “secure HIPAA-compliant video link” or “audio-only call”)
- Reason for audio-only (if applicable) patient lacked device, declined video, or had no internet access
- Patient consent for the telehealth encounter, especially for audio-only mental health visits
- Duration of the visit
- Clinical notes that are as detailed as those written for in-person visits
From an audit readiness perspective, POS 10 is a “high-visibility” field for OIG and RAC auditors. Because the reimbursement difference between POS 10 and POS 02 is substantial, auditors look for “upcoding” patterns where providers might incorrectly use POS 10 for patients actually located in lower-paying facility settings.
The 5 Most Common POS 10 Billing Mistakes
Industry reviews show that 20 to 30 percent of telehealth claims are denied due to errors related to modifiers or Place of Service codes. Here are the five errors that appear most frequently:
1. Using POS 02 Instead of POS 10 for Home-Based Visits
One of the most common mistakes is selecting POS 02 when the patient is actually at home. When a home-based visit is coded with POS 02, the claim may be processed under the wrong reimbursement rate or flagged for inconsistency. This mismatch can trigger underpayments or denials because the payer cannot verify the correct care setting.
2. Missing the Required Modifier
Incorrect POS coding often leads to a “mismatch denial.” Payers now use automated logic to cross-reference the Place of Service with the appended modifiers. For example, billing POS 10 while failing to include Modifier 95 (for video) or Modifier 93 (for audio-only) creates a logical contradiction in the payer’s system. It often results in a “hard denial” that requires a manual appeal.
3. Confusing POS 10 with POS 12 (Home)
A common mistake is using POS 12 even when the service was delivered by telehealth. If the patient is at home and the service is provided through telecommunication technology, CMS’s current definition points to POS 10, not POS 12. POS 12 is for in-person home visits, not telehealth.
4. Using POS 10 for Non-Covered Services
CMS says some non-face-to-face services, such as remote monitoring and chronic care management, are not governed by the same Medicare telehealth rules. Always verify the service is on CMS’s current telehealth services list before applying POS 10.
5. Incomplete Documentation
According to the American Academy of Family Physicians, nearly 30% of telehealth claims are denied due to documentation issues. Missing elements like the patient’s location, consent, or communication method can turn a correct code into a denied claim.
Payer-Specific Rules: Medicare, Medicaid, and Commercial
POS 10 requirements are not identical across all payers. Here is what to know for each:
Medicare
Medicare has the clearest and most detailed POS 10 rules. POS 10 became mandatory for many telehealth claims after CMS updates in 2022, and as of 2025, it remains a key compliance requirement for Medicare. Using this code correctly ensures accurate reimbursement, prevents downcoding, and reduces the risk of claim denials or post-payment audits.
Medicaid
Medicaid has state-specific rules, and some states require additional telehealth attestations. The rules vary significantly by state, so always check your specific state’s Medicaid telehealth billing policy before submitting claims.
Commercial Insurers
Some commercial payers may require modifier FQ or FR in addition to Modifier 95 for audio-only mental health telehealth claims verify in payer policy. Commercial payers may also have their own lists of covered telehealth services that differ from the Medicare list.
CMS says providers should check with individual payers, including Medicare, Medicaid, and private insurers, for reimbursement policies regarding POS codes.
Behavioral and Mental Health: Special POS 10 Rules
Mental and behavioral health providers have some specific advantages under the current telehealth framework. Mental and behavioral health telehealth services remain permanently exempt from geographic and originating site restrictions, meaning they can be provided from a patient’s home regardless of location.
It is especially significant for rural patients, where geographic restrictions used to block access to mental health telehealth. Since those restrictions no longer apply to behavioral health, POS 10 opens up full reimbursement potential for providers in this specialty.
Effective November 1, 2023, Optum Behavioral Health requires all behavioral health telehealth claims to include a mandatory POS code, either POS 02 or POS 10. It applies to all health plans across all lines of business, including commercial, Medicare Advantage, and Medicaid.
Compliance Risks and Audit Exposure
Getting POS 10 wrong is not just a revenue problem it is a compliance problem. Overpayment recoupment is a real risk: if a payer determines the location was misclassified, reimbursement can be reclaimed months later. Repeated misreporting of POS could be interpreted as intentional misrepresentation.
According to the Centers for Medicare & Medicaid Services (CMS), billions of dollars in improper Medicare payments each year are linked to insufficient documentation and incorrect claim coding. A large portion of these errors stems from place of service coding mistakes that disrupt the alignment between medical necessity, clinical setting, and reimbursement policy.
The best protection against audits is a combination of accurate coding, thorough documentation, and routine internal review.
Best Practices for Clean POS 10 Claims
Implementing a structured approach to telehealth billing will significantly reduce your denial rate and protect your revenue. Here are the steps every billing team should follow:
- Confirm patient location at the start of every telehealth call never assume the patient is home based on a prior visit.
- Select POS 10 only when the patient is in a private residence, not when they are at a clinic, hospital, or facility.
- Always pair POS 10 with the correct modifier Modifier 95 for video visits, Modifier 93 for audio-only when video is unavailable or declined.
- Use in-person E/M CPT codes (99202–99215) for home-based telehealth, not the 98000–98015 telemedicine range.
- Document patient location, consent, communication method, and visit duration in every note.
- Update your EHR and practice management system to include “Telehealth-Home (POS 10)” as a selectable option that auto-populates with the correct modifier.
- Run pre-submission claim scrubs to catch POS/modifier mismatches before the claim reaches the payer.
- Verify each payer’s telehealth rules at least annually, as Medicare, Medicaid, and commercial insurers all update their policies regularly.
- Train billing staff quarterly on common denial trends and POS coding changes.
- Conduct internal audits on a sample of telehealth claims each month to catch errors before they become patterns.
POS 10 and the Provider Location Rule
There is one additional detail that surprises many providers. Through the end of 2025, providers may continue using their enrolled practice location instead of their home address for Medicare telehealth services provided from their own home.
It means a physician working from their personal residence can still bill under their practice address. Both provider and patient must be located in the U.S. or its territories during the encounter.
Summary
POS 10 is the correct billing code whenever a telehealth service is delivered to a patient who is physically located in their home. It unlocks the higher non-facility reimbursement rate, averages about $34 more per claim than POS 02, and is now permanently confirmed by CMS as a required code under the 2025 Physician Fee Schedule.
To bill POS 10 correctly:
- Confirm the patient is at home (not at a clinic or facility)
- Use standard E/M CPT codes (99202–99215)
- Add Modifier 95 for video or Modifier 93 for audio-only
- Document the patient’s location, consent, communication method, and visit details.
- Verify your payer’s specific requirements before submitting.
Getting POS 10 right is not complicated, but it does require consistent training, updated systems, and thorough documentation. Done well, it protects your revenue, keeps your practice compliant, and ensures patients continue to access the virtual care they need.
