Behavioral Health POS question

We are a psychiatric health system. We have a new program with GBMC where our psychiatrist are going to a Primary Care setting and providing outpatient care. We do not own the office, the primary care practice owns the office. We have been using POS 11 for the past couple of months. We are now being told by a consultant that because we do not own the practice we cannot use POS 11. She is saying that we should use POS 99 (other), if we use this POS every claim will be denied, it will become a mess. Do you have any thoughts on us using POS 11? I would appreciate any thoughts.

Thank you,



  • Sharon,Do you pay FMV rent when your physician is there? I would establish a fair market value for rent (based on square footage, utility use, if included, and time, not on referrals) and then you can bill POS 11. Billing POS 11 implies that you have expenses related to owning or renting an office.
    Dori Roth, MBAAssociate InnoMed Management Group, LLC 

  • Dori,

    We do not pay FMV rent. We have an agreement with the partner to use their space. Per Stark revisions we are not required to pay rent. Without paying rent will CMS pay for POS 11?

    Thank you,

  • edited May 2017
    If you do not pay rent or have associated overhead expenses you cannot claim place of 11. POS 11 includes monies for overhead expenses such as heat, lights, staff etc. Since you do not have those you would be getting paid incorrectly. POS issues have been on the OIG work plan for several years so I would be very careful.

  • Sharon, I believe they will pay and may never find out; however, I agree with the consultant that the POS is not 11 and that you don't really have any other option besides POS 99. It is assumed that you have some sort of overhead to bill POS 11, and that is why there is a payment differential for facility vs. office.

  • I agree with Jan. What Stark revisions are you referring to that lends you to believe rent is not necessary?


    Kris Cuddy, CPC, CIMC
    Healthcare Compliance Analyst
    Compliance Office
    Michigan State University HealthTeam
    East Lansing, MI
    Ofc: 517-355-4547
    Fax: 517-353-5292

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