POS 02 vs POS 10: Which Telehealth Place of Service Code to Use

Both codes are telehealth place-of-service (POS) codes maintained by CMS, and the descriptors are nearly identical except for one phrase about where the patient is sitting.

POS 02 — Telehealth Provided Other than in Patient's Home. Official descriptor: 'The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.' Use POS 02 when the patient is at a clinic, a hospital outpatient department, a skilled nursing facility, a school-based health center, or any originating site that is not the patient's residence.

POS 10 — Telehealth Provided in Patient's Home. Official descriptor: 'The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.' Use POS 10 when the patient is at home.

The key word in both descriptors is 'patient' — the POS code describes where the patient is, not where the provider is. A physician sitting in a clinic exam room delivering a video visit to a patient at home still bills POS 10, because POS reflects the patient's (originating-site) location. This trips up a lot of front-end teams who assume POS describes the billing provider's location.

Historically there was only one telehealth POS code — POS 02 — and it covered all telehealth regardless of where the patient was. Effective January 1, 2022, CMS introduced POS 10 and simultaneously narrowed the POS 02 descriptor to 'other than in patient's home,' splitting the single code into the two we use today.

Before 2022, telehealth billed under POS 02 paid at the facility rate under the Medicare Physician Fee Schedule (PFS). That made sense in the original telehealth model, where the patient traveled to an originating-site facility (a rural clinic, a hospital) and the facility billed an originating-site fee (HCPCS Q3014) while the distant-site provider billed POS 02 at the facility rate.

The pandemic flipped that model. Patients started receiving telehealth at home, where there is no originating-site facility absorbing overhead — the practice still carries the cost of scheduling, intake, clinical staff, and technology. Paying those home visits at the lower facility rate underpaid practices for work that more closely resembled an in-office (non-facility) encounter.

CMS's fix, effective January 1, 2022, was to create POS 10 ('Telehealth Provided in Patient's Home') and assign it the non-facility payment rate — the same rate Medicare pays for POS 11 (office). POS 02 was retained for telehealth where the patient is in a facility and kept its facility payment rate. So the split is fundamentally a payment-policy split:

• Patient at home → POS 10 → non-facility rate (higher, matches in-office).
• Patient in a facility → POS 02 → facility rate (lower, because facility overhead is billed separately).

In our telehealth billing audits, this is the single most common silent-leakage pattern we find: practices that adopted telehealth in 2020-2021 under POS 02 and never updated their templates after the 2022 change, so every home-based video visit posts at the facility rate and underpays by the facility/non-facility differential on every line.

The facility vs non-facility split is built into the Medicare PFS itself. Every CPT code has two practice-expense RVU values — a facility PE RVU and a non-facility PE RVU — and the non-facility value is usually higher because it assumes the practice bears the full overhead. POS 02 pulls the facility rate; POS 10 and POS 11 pull the non-facility rate.

Side-by-side comparison:

Worked dollar example. Take a mid-level established-patient telehealth visit. Suppose under the CMS PFS the code has a facility allowable of about \$76 and a non-facility allowable of about \$93 in a given locality (illustrative — your exact dollars vary by code, year, and MAC locality; verify against the current CMS PFS lookup). Billing that home video visit under POS 02 instead of POS 10 leaves roughly \$17 per visit on the table. A behavioral-health or primary-care provider running 25 home telehealth visits a week loses about \$425/week, or ~\$22,000/year, purely to a POS code that should have been 10. Across a multi-provider group the leakage scales linearly and is completely invisible on the EOB — the claim pays, it just pays the wrong rate.

Do not invent exact dollars for a contract you have not checked: pull the real facility and non-facility allowables for your specific codes from the CMS Physician Fee Schedule Look-Up Tool, and confirm commercial allowables against your contracts, because commercial parity varies by payer and state.

The decision is almost entirely about patient location at the time of the visit. Use this logic:

1. Was the visit delivered via telecommunication (audio-video or, where allowed, audio-only)? If no — it is in person — use POS 11 (office) or the appropriate facility POS, not a telehealth code.
2. Where was the PATIENT physically located during the telehealth visit?

• In their home (private residence, including temporary lodging or a relative's home where they receive care) → POS 10.
• Anywhere else — a clinic, hospital outpatient department, SNF, school clinic, employer site, or another originating-site facility → POS 02.

1. Append the correct telehealth modifier. For Medicare, append modifier 95 for synchronous audio-video telehealth, and modifier 93 for audio-only (when the code and patient circumstances allow audio-only). Both POS 02 and POS 10 take the modifier — the POS tells the payer it was telehealth and where, the modifier tells it the modality.
2. Confirm payer-specific overrides. Some commercial and Medicaid payers still want POS 11 with modifier 95 (telehealth billed 'as if in office'), and some want POS 02 for everything. Always default to the payer's published telehealth policy; the POS 02/10 split below is the Medicare baseline.

The most common operational error is treating POS as the provider's location. It is not. A clinician at the hospital seeing a homebound patient on video bills POS 10 because the patient is home — even though the provider is in a facility.

POS 02 vs POS 10 is a Medicare construct, and other payers do not all follow it. Treat the table below as the starting framework, then verify each payer's current telehealth policy because these rules change frequently and vary by state.

Because commercial and Medicaid handling genuinely varies, build a payer-by-payer telehealth POS grid for your top payers and keep it current. The single most expensive assumption in telehealth billing is that 'everyone follows Medicare.' They do not — a payer that wants POS 11 + 95 will deny or reprocess a POS 10 claim, and a payer that wants POS 02 will not necessarily pay POS 10 at the non-facility rate. When in doubt, the contract and the payer's telehealth policy bulletin win. For the broader telehealth coverage rules, see our guide to medical billing for telehealth providers.

A wrong telehealth POS rarely produces a clean, obvious denial — that is what makes it dangerous. More often it underpays silently or triggers a downstream reprocessing/take-back. Here are the named CARC codes you will see and how to work them.

The last row is the one that hurts most because there is no worklist alert — the claim adjudicates and posts. The only way to catch it is a payment-posting audit comparing your telehealth allowables to the CMS non-facility rate. In our denial management and posting reviews, POS-driven underpayment on telehealth is one of the highest-ROI catches because it is recurring and systemic, not one-off. For the broader place-of-service framework (office POS 11 vs hospital outpatient POS 22 and the facility/non-facility logic behind all of this), see POS 11 vs POS 22.

Getting POS right is both a payment issue and a compliance issue — billing POS 10 (the higher-paying code) when the patient was actually in a facility is an overpayment that a payer can claw back, so the documentation has to support the location you billed.

Document and confirm for every telehealth claim:

• Patient's physical location at the time of service (home vs facility) — this is what determines POS 10 vs POS 02. Note it in the encounter.
• The modality — synchronous audio-video (modifier 95) vs audio-only (modifier 93). The note should reflect that real-time interactive communication occurred.
• Patient consent to telehealth where required by the payer or state.
• The originating and distant site as applicable, and whether an originating-site facility fee (Q3014) is being billed separately (it would not be when the patient is at home).
• Provider location/licensure consistent with the state the patient is in at the time of service (cross-state licensure is a separate compliance gate from POS).
• The correct telehealth code list — confirm the CPT/HCPCS you billed is on the payer's covered-telehealth-services list for the date of service.

Quick compliance rule of thumb: if you cannot prove from the record that the patient was at home, do not bill POS 10 just because it pays more. Bill the POS that matches reality, document the location, and let the payment follow. Consistent, defensible POS coding is what keeps the higher POS 10 payments from turning into refund requests during an audit.

Practices that run clean on telehealth POS do five things consistently:

1. EHR/PM templates were updated after January 1, 2022 to offer POS 10 for home telehealth, not the legacy POS 02. Any template still defaulting telehealth to POS 02 is leaking the facility/non-facility differential on every home visit.
2. Patient location is captured at intake, not assumed — front-end staff confirm whether the patient is home or in a facility, because that single data point drives POS 10 vs POS 02.
3. The telehealth modifier is paired to the POS automatically (95 for audio-video, 93 for audio-only) so claims do not bounce on CARC 4 or CARC 5 for a missing/mismatched modifier.
4. A payer-by-payer telehealth POS grid is maintained for the top payers, because commercial and Medicaid rules diverge from Medicare and change often.
5. Payment posting audits telehealth allowables against the CMS non-facility rate to catch silent POS 02 underpayments that never hit a denial worklist.

In our telehealth audits, the practices losing the most money are not the ones getting denials — they are the ones whose telehealth claims all pay cleanly under POS 02 at the facility rate, year after year, because nobody updated the template after CMS created POS 10. If your team does not have the bandwidth to keep the POS grid current and audit telehealth allowables, outsourced telehealth medical billing services can own the POS logic, the payer grid, and the underpayment recovery end to end.