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What is the difference between POS 02 and POS 10?
Both are Place of Service codes for telehealth, and the only difference is where the patient was. POS 10 is telehealth with the patient in their home. POS 02 is telehealth with the patient anywhere else.
| POS 10 | POS 02 | |
|---|---|---|
| Where the patient was | At home, in a private residence | Not at home: a clinic, hospital, workplace, school or anywhere else |
| Medicare pays | The non-facility rate (higher) | The facility rate (lower) |
| Use it when | The visit note says the patient was home | The visit note says the patient was somewhere else |
CMS defines POS 10 as telehealth where the patient is in their home, meaning a private residence and not a hospital or other facility. It defines POS 02 as telehealth where the patient is not in their home. [1]
Why does the same visit pay two different amounts?
Medicare pays most services at one of two rates, and the difference is overhead. The non-facility rate assumes your practice carries the cost of running the visit, and the facility rate assumes a facility shares it.
CMS states that POS 10 claims are paid at the non-facility rate and POS 02 claims at the facility rate, and that the audio-only or video modifier does not change the rate. Only the place of service code does. [2]
So a claim that says POS 02 for a patient who was really at home tells Medicare a facility was involved when none was. Medicare believes the claim and pays the lower amount.
When did the POS 10 payment rule start?
Medicare has paid POS 10 telehealth at the non-facility rate since January 1, 2024. Before that, many practices used POS 02 for every video visit, and some systems still default to it.
- January 1, 2022: POS 10 took effect and POS 02 was narrowed to telehealth outside the home. Medicare began accepting both on April 1, 2022. [1]
- January 1, 2024: POS 10 claims began paying at the non-facility rate. CMS issued the instruction to its contractors on June 6, 2024, effective for dates of service from January 1, 2024. [2]
- Today: CMS still tells practitioners to use POS 10 for patients at home and POS 02 for patients elsewhere, with home visits paid at the non-facility rate. [3]
What does the gap look like on a real claim?
The gap depends on the service and your location, so treat any single example as an illustration. One published case shows how large it can be for a therapy session.
A billing company described a behavioral health provider in Chicago billing Medicare for 60-minute psychotherapy sessions by telehealth under POS 02, with patients at home. Payments were about $102 per visit; after the code was corrected to POS 10, the same sessions paid about $126.71. Single source[8]
For a sense of scale, if a practice were underpaid $15 on each of 40 home telehealth sessions a week, that would add up to $600 a week. This is arithmetic for illustration, not a figure from any practice.
What happens if the code is wrong in either direction?
POS 02 for a patient at home quietly underpays you. POS 10 for a patient who was not at home overpays you, and an overpayment you know about has to be returned.
| POS 02 for a patient at home | POS 10 for a patient not at home | |
|---|---|---|
| What happens | The claim pays at the lower rate, usually with no denial or warning | The claim pays at the higher rate the visit did not qualify for |
| What it means | Money you earned and did not receive, on every affected visit | An overpayment owed back to Medicare |
| What to do | Correct the claims, within each payer's filing limits | Report and return it within the federal deadline below |
Federal rules give 60 days from when an overpayment is identified to report and return it. That deadline is suspended while you complete a timely, good-faith investigation into related overpayments, for up to 180 days. [4]
A health law firm notes that a contractor finding repeated mismatches can demand repayment across a sample and extend it across the whole look-back period. Where a pattern looks deliberate, the firm says a False Claims Act referral is possible. Single source[9]
Which situations are easy to get wrong?
Most mistakes come from confusing the clinician's location with the patient's, or from places that are not quite home. When in doubt, write down exactly where the patient was.
| Situation | How to think about it |
|---|---|
| Patient at home, clinician working from home | Still POS 10. The code follows the patient, never the clinician. |
| Patient joins from work, school or a parked car | Not a private residence, so generally POS 02. |
| Patient staying somewhere temporary | Write down exactly where they were, then check with your Medicare contractor before choosing. |
| In-person visit in the patient's home | Not telehealth, so not POS 10. In-person home visits use POS 12 (Home). |
| Audio-only phone session | Location still decides POS 02 or POS 10. Modifier 93 marks audio-only and modifier 95 marks video, and neither changes the rate. |
CMS lists POS 12 (Home) separately from POS 10 and states that modifiers 93 and 95 do not change the payment rate. [1][2]
How do auditors find place of service errors?
They compare data that already exists, such as the rate on your claim against records showing where care happened. The Office of Inspector General has found millions of dollars in place of service errors this way.
None of these audits was about POS 02 and POS 10, which are newer. They show the method: if your notes say the patient was home and your claims say otherwise, the mismatch shows up in the data alone.
- A 2015 audit found Medicare contractors potentially overpaid physicians about $33.4 million from 2010 to 2012 for services billed at the non-facility rate that were performed in facilities. [5]
- A 2023 audit of 2019 and 2020 claims found $22.5 million in overpayments where Medicare paid the non-facility rate while patients were facility inpatients. [6]
- A 2018 telehealth audit compared practitioners' telehealth claims with the matching facility claims and reviewed 191,118 claims worth $13.8 million that had no match. [7]
Does this apply to commercial insurance and Medicaid?
Not automatically. The rule above is Medicare's, and commercial plans, Medicaid plans and Medicare Advantage plans each set their own telehealth billing rules and rates.
Use the patient's location as the starting point for every payer, then check each major payer's telehealth policy or contract before you change a template. Fixing Medicare and assuming every other payer follows can swap one quiet error for another.
How can you check your own claims this week?
Compare the patient location in a small sample of visit notes with the code on each claim. Twenty claims is enough to tell you whether you have a problem.
Pull a small sample. Take 20 recent Medicare telehealth claims across your clinicians.
Read the note, not the claim. Find where each note says the patient was. If a note does not say, that is a finding on its own.
Compare the two. Home should match POS 10, and anywhere else should match POS 02. Count the mismatches and note which way they run.
Check your default. Open the template or EHR setting that builds telehealth claims and see which code it fills in on its own.
Add one question to every visit. Have clinicians record where the patient is at the start of each telehealth session, in the same place in the note every time.
Sources (9)
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Every source behind this guide, with the label we gave it and the date we read it.
Verified Official and primary sources
- [1]CMS, Place of Service Code Set. Definitions and effective dates of POS 02, POS 10 and POS 12. Read October 17, 2026.
- [2]CMS, Transmittal R12671CP: Billing and Payment for Telehealth Services with POS 10. POS 10 paid at the non-facility rate from January 1, 2024; POS 02 at the facility rate; modifiers do not change the rate. Read October 17, 2026.
- [3]CMS, Telehealth FAQ (updated October 9, 2026). Current POS guidance; behavioral health telehealth at home made permanent. Read October 17, 2026.
- [4]eCFR, 42 CFR 401.305: Requirements for reporting and returning of overpayments. The 60-day deadline and the suspension of up to 180 days for a good-faith investigation. Read October 17, 2026.
- [5]HHS Office of Inspector General, Incorrect Place-of-Service Coding Resulted in Potential Medicare Overpayments Costing Millions (A-01-13-00506, 2015). About $33.4 million in potential overpayments, January 2010 to September 2012. Read October 17, 2026.
- [6]HHS Office of Inspector General, Medicare Paid Millions More for Physician Services at Higher Nonfacility Rates (A-04-21-04084, 2023). $22.5 million in overpayments on 2019 and 2020 claims. Read October 17, 2026.
- [7]HHS Office of Inspector General, CMS Paid Practitioners for Telehealth Services That Did Not Meet Medicare Requirements (A-05-16-00058, 2018). 191,118 telehealth claims worth $13.8 million with no matching facility claim. Read October 17, 2026.
Single source One report each
- [8]Upstate Healthcare Admin, Danielle Wagar, Getting Paid Correctly for Medicare Telehealth: Understanding POS 10 (April 2, 2026). The reported example of about $102 per visit under POS 02 and about $126.71 under POS 10. Read October 17, 2026.
- [9]Health Law Alliance, Anthony Mahajan, Telehealth Place of Service Coding Errors (September 18, 2026). A law firm view on recoupment, extrapolation and False Claims Act referrals. Read October 17, 2026.