Telehealth POS 10 vs 02: Which Code to Bill and When

Use POS 10 when the patient is at home during the telehealth visit. Use POS 02 when the patient is anywhere else. The code follows the patient's location, not the provider's, and it changes how Medicare pays the claim. That makes it a two-digit field that can quietly cost a practice money, or draw an audit question, if it is wrong.

This guide explains what each code means, how payment differs, how to pick the right one at the front desk and in the chart, and where commercial and Medicaid payers depart from Medicare.

TL;DR

• POS 10 is telehealth with the patient in their home. POS 02 is telehealth with the patient somewhere other than home (HHS Telehealth.gov).
• Medicare pays POS 10 at the non-facility rate and POS 02 at the facility rate (CMS R12671CP).
• Your documentation must show where the patient was. A default POS on every telehealth claim is the most common error.
• Medicaid and commercial payers can require a different POS or modifier than CMS, so check each payer's policy.
• Build the patient-location check into scheduling and the visit note, then audit claims for mismatches.

Table of Contents

• What POS 10 and POS 02 mean
• How Medicare pays POS 10 versus POS 02
• How to choose the right code, step by step
• POS is not the modifier
• What to document so the code holds up
• Commercial payers and Medicaid do not always follow Medicare
• Where POS sits on the CMS-1500
• Common errors and how to catch them
• Our perspective
• See what your telehealth claims are leaving behind
• FAQ
• Sources

What POS 10 and POS 02 mean

The place of service code is a two-digit entry on the CMS-1500 professional claim. It tells the payer the setting where the service was delivered. For telehealth, two codes carry the location story:

Those definitions match the Medicare fee-for-service billing guidance on Telehealth.gov. The distinction is the patient's location only. The clinician can be in the office, at home, or elsewhere. The patient's side of the screen decides the code.

For a broader refresher on the full code set, our place of service codes billing and compliance guide covers where telehealth fits next to POS 11 (office) and the facility codes.

Where the codes came from

POS 10 is relatively new. CMS added it effective January 1, 2022, with implementation on April 4, 2022, and revised the description of POS 02 at the same time (CMS MM12427). Before that, POS 02 covered all telehealth, whether the patient was at home or not.

The split exists so payers can see where the beneficiary was. For Medicare telehealth, CMS ties that setting information directly to the payment rate, as the R12671CP transmittal explains.

Since January 1, 2024

CMS requires Medicare telehealth claims to use POS 10 when the patient is in their home at the time of service, per the same R12671CP transmittal. Before 2024, POS 02 was paid at the non-facility rate regardless of location. That temporary arrangement is over, so the code you choose now determines the rate.

How Medicare pays POS 10 versus POS 02

This is why the choice matters. Per CMS, Medicare pays telehealth services reported with POS 10 at the Medicare Physician Fee Schedule non-facility rate. Services reported with POS 02 are paid at the facility rate (CMS R12671CP).

In most physician fee schedule lines, the non-facility rate is higher than the facility rate, because the non-facility rate includes practice expense that a facility would otherwise absorb. So the same CPT code can pay differently depending on the POS digit attached.

That creates risk in both directions:

• POS 02 billed when the patient was at home. You are likely underpaid on every claim. This is revenue leakage that no denial will ever flag, because the claim pays cleanly at the wrong rate.
• POS 10 billed when the patient was in a clinic or other site. You are paid the higher non-facility rate for a service that should have been paid at the facility rate. That is an overpayment exposure in a payer audit.

Neither error produces an obvious rejection. Both show up only when someone compares the claim to the chart.

A simple illustration

Take a established-patient visit billed with the same E/M code and modifier 95 on two different days. On Monday the patient takes the video call from the living room. On Thursday the patient joins from a satellite clinic's exam room with a nurse present. Monday is POS 10. Thursday is POS 02. The CPT code is identical, the clinician is identical, and the payment is not. If your scheduling template stamps POS 02 on both, you lose money on Monday. If it stamps POS 10 on both, you are overbilled on Thursday.

The originating site fee is separate

When a patient is at a qualifying originating site such as a clinic, that site may bill its own facility fee. For calendar year 2026, the Medicare originating site facility fee (HCPCS Q3014) is 80% of the lesser of the actual charge or $31.85 (CMS R13507CP). Note that POS 10 does not apply to originating site facilities billing that fee (CMS R12671CP). If your practice owns the site where the patient sits, bill Q3014 in addition to the distant-site professional service, and keep POS 02 on the professional claim.

How to choose the right code, step by step

The rule is short: POS 10 when the patient is in their home, POS 02 when the patient is not (CMS R12671CP). Applying it reliably takes a process.

1. Ask at scheduling. Add a required field: "Where will the patient be during the visit?" Options: home, clinic or other facility, other (workplace, car, a friend's house).
2. Confirm at check-in. For same-day video visits, the medical assistant or the clinician confirms location at the start of the call. Patients move around.
3. Record it in the note. One line is enough: "Patient located at home (private residence) for this visit." Or: "Patient located at [site name]."
4. Map location to POS in the claim rules. Home maps to 10. Everything else telehealth maps to 02. Do not let the practice management system default.
5. Review exceptions. Flag visits where location is blank, or where it contradicts the POS on the claim.

Edge cases that trip up staff

• Patient in a hotel, short-term rental, or a relative's house. Whether a temporary residence counts as "home" is a payer-policy question. Check the payer's definition and document what you relied on. Do not guess in the moment.
• Patient in a nursing facility, group home, or assisted living. These are tied to other place-of-service categories and payer rules. Verify the payer's treatment before defaulting to 10.
• Patient in a car or at work. Not a home. POS 02 is the logical choice under the definition of "other than in the patient's home."
• Patient moved mid-visit. Code to where the patient was for the service, and note the change.

If you are unsure for a specific payer, ask the payer or consult your compliance lead before the claim goes out, not after it is denied.

POS is not the modifier

Teams often mix up the place of service code and the telehealth modifier. They do different jobs.

• POS 02 or 10 reports the patient's location.
• Modifier 95 reports a real-time audio-video service.
• Modifier 93 reports an audio-only service.

CMS uses exactly this pairing in its encounter data guidance: modifier 95 for real-time audio-video telehealth and POS 02 or 10 to indicate the patient's location, with modifier 93 for audio-only (CMS risk adjustment and encounter data memo). A claim can be right on one and wrong on the other, so check both. Our modifier usage guide for physician billing walks through the modifiers that most often cause denials.

What to document so the code holds up

The CMS telehealth toolkit tells providers to document and code for POS, complete documentation at the time of service, and verify that the documentation supports the codes used. It also reminds providers to check that the service is on the Medicare telehealth list and to use modifier 95 for real-time services (CMS Telehealth for Providers). The list is large: more than 250 codes are eligible for reimbursement, and accurate billing matters (HHS Telehealth.gov).

A defensible telehealth note includes:

• The patient's location at the time of service (home or named site).
• The modality: real-time audio-video or audio-only.
• Consent, where your payer or state requires it.
• The clinician's location, if the payer requires it.
• Time or medical decision-making that supports the E/M level billed.

If the location line is missing, an auditor cannot confirm the POS. Treat that the same as any other unsupported element: the claim is exposed. For a fuller checklist, see our telehealth coding compliance guide.

Commercial payers and Medicaid do not always follow Medicare

Everything above describes Medicare fee-for-service. Other payers can differ. NACHC's billing tip sheet notes that each payer may require a modifier or POS different from CMS or the state Medicaid plan, so review the applicable payer and state Medicaid plan (NACHC telehealth billing tip sheet). CMS says the same thing in plain terms: billing and reimbursement requirements vary among payers and geographic locations (CMS Telehealth for Providers).

Two state examples show how much it moves:

• Ohio Medicaid. Effective January 1, 2027, Ohio will no longer accept POS 02 or 10 on professional claims when Medicaid is the primary payer, unless stated otherwise. Patient-location modifiers are used as applicable (Ohio Medicaid managed care telehealth guidelines).
• Oregon Medicaid. Oregon did not use POS 10 at first and later accepted it for dates of service on or after January 1, 2024 (Moda Health telehealth policy).

The practical takeaway: keep a payer-by-payer telehealth grid. For each major payer, record which POS they accept, which modifier they want, whether audio-only is covered, and where the policy lives. Review it at least once a year and whenever a payer bulletin lands.

Where POS sits on the CMS-1500

On the paper-format CMS-1500 claim, the place of service code goes in item 24B, one per service line. Electronic 837P claims carry the same information in the service line. The important point is that POS is per line, not per claim, so a patient seen both in person and by video in the same billing cycle needs the correct POS on each line. Confirm the exact field placement against your clearinghouse's specifications.

Common errors and how to catch them

A monthly sample is enough to find most of these. Pull 20 telehealth claims per provider, compare POS and modifier to the note, and track the mismatch rate. If the rate is more than a few percent, the cause is almost always a template or workflow default, not individual clinicians.

Our perspective

Most practices we talk to believe their telehealth claims are clean because they are being paid. That is the trap. A wrong POS rarely triggers a denial. It just pays at the wrong rate, in the practice's disfavor or in the payer's, and nobody notices until a payer audit or a year of missing revenue.

We built HIMShield to look at the claim and the chart together. Our platform scans EHR data before claims go out and flags where documentation and codes disagree, including location-dependent codes like POS. It quantifies the gap per provider and per payer in a Revenue Leakage Report, drafts corrections for physician e-signature, and assembles submission-ready responses if a payer comes asking.

For an independent practice with no compliance department, that is the difference between hoping the claims are right and knowing. A telehealth POS check takes seconds when it is automated, and hours when it is done by hand during an audit.

Elena

See what your telehealth claims are leaving behind

If you want to know whether your POS 10 and POS 02 claims match your documentation, our free 30-day audit scans your EHR data and quantifies coding, documentation, and charge-capture gaps by provider and payer, with a performance guarantee. It works without new staff or software training for your team. Request your free 30-day Revenue Leakage Audit, or learn more about our HIM compliance engagement.

FAQ

Can I bill POS 10 if the provider is also at home?

Yes, if the patient is at home. The code reflects the patient's location, not the clinician's. A provider working from home with a patient at a clinic would bill POS 02. Some payers also ask for the provider's location, so check each payer's policy.

Does POS 10 always pay more than POS 02?

For Medicare, POS 10 is paid at the non-facility rate and POS 02 at the facility rate (CMS R12671CP). The size of the difference depends on the CPT code and the fee schedule. Other payers may price telehealth differently, so verify in your contract or policy.

Do I still need modifier 95 with POS 10 or 02?

For real-time audio-video services, yes where the payer requires it. CMS guidance pairs modifier 95 with POS 02 or 10, and uses modifier 93 for audio-only (CMS encounter data memo). The POS reports location. The modifier reports how the visit was delivered.

Do Medicaid and commercial plans accept POS 10?

Not uniformly. Requirements vary by payer and state, and some states have changed their acceptance over time (NACHC tip sheet). Check each payer's current telehealth policy before you build billing rules.

Sources

• HHS Telehealth.gov: Billing and coding Medicare fee-for-service claims
• CMS transmittal R12671CP (web page)
• CMS transmittal R12671CP (PDF)
• CMS MM12427: New and modified place of service codes for telehealth
• CMS transmittal R13507CP
• CMS: Telehealth for Providers, What You Need to Know
• CMS: Risk Adjustment Processing System and encounter data memo
• NACHC: Telehealth billing tip sheet
• Ohio Medicaid: Telehealth services guidelines for managed care entities
• Moda Health: Telehealth and telemedicine policy

Recommended

• Place of Service Codes: A Billing and Compliance Guide
• Telehealth Coding Compliance: 2026 Rules and Checklist
• Modifier 26 vs. TC: U.S. Coders’ Checklist Starts With Indicator 1