Key Takeaways
- Place Of Service (POS) codes tell insurance where a session happened. Your CPT code tells them what happened.
- For telehealth, the client's location decides the code: POS 10 if they're home, POS 02 if they're somewhere else.
- POS 11 is the go-to code for in-person sessions in your office.
- Since January 1, 2024, Medicare has paid telehealth to clients at home (POS 10) at the higher non-facility rate.
- Medicare, Medicaid, and commercial payers don't all follow the same rules, especially for modifiers.
- Most POS mistakes can be fixed with a corrected claim, as long as you catch them in time.
It's 6 p.m. You just finished your last telehealth session, and you're staring at a claim wondering: is this a 02 or a 10?
Place of service codes feel like a tiny technicality until a claim gets denied or quietly paid less than it should. Two digits, surprisingly big consequences.
Let's sort out the place of service codes therapists actually use, how telehealth coding works, and how the rules differ between Medicare, Medicaid, and commercial payers.
What Are Place of Service Codes?
Place of service codes are two-digit codes that describe the setting where a service was provided. The Centers for Medicare & Medicaid Services (CMS) maintains the official list, which is used on professional claims across the industry.
An easy way to remember it:
- CPT code = what you did (like 90837)
- POS code = where you did it
On a paper CMS-1500 claim, the POS code goes in Box 24B. In most EHR and billing software, it's a field or dropdown on the claim or appointment.
Why it matters: the POS code can change which rate a payer uses to pay your claim. CMS itself notes that you should check with each payer (Medicare, Medicaid, or private insurance) for their reimbursement policies on these codes. More on that below.
Telehealth Place of Service Codes: POS 02 vs. 10
This is the question therapists ask most, so let's start here.
Back in the day, POS 02 was the only telehealth code. In 2022, CMS split telehealth into two codes based on one thing: where the client is during the session.
Place of Service 10: Client Is at Home
Use POS 10 (Telehealth Provided in Patient's Home) when your client joins the session from their home. CMS defines home as a private residence, not a hospital or other facility.
For most therapy practices, this is the telehealth code you'll use most often. Client on their couch, in their bedroom, or at their kitchen table? POS 10.
Place of Service 02: Client Is Somewhere Else
Use POS 02 (Telehealth Provided Other than in Patient's Home) when your client joins from anywhere that isn't their home. Think:
- Their office at work
- A school or college campus
- A parked car outside the gym (it happens)
Your Location Doesn't Change the Code
Here's the part that trips people up: where you are doesn't matter. Whether you're in your office, your home office, or a coffee shop you should probably not be doing therapy from, the code depends on the client's location.
According to CMS's telehealth FAQ, if practitioners have a physical practice location but provided telehealth from their home, they can bill from their physical practice location as if the service happened in person.
Quick tip: ask where clients will be joining from at intake, check in now and then (people move, go back to the office, visit family), and note the client's location in each session note. That documentation backs up your code if a claim ever gets questioned.
Pairing POS Codes With Modifiers 95 and 93
For telehealth, the POS code often travels with a modifier:
- Modifier 95: real-time audio and video
- Modifier 93: audio-only (phone)
Not every payer wants the same combination, though. Some require the modifier, and some mainly rely on the POS code. That's why the payer section below matters so much. Check each payer's telehealth policy before you assume.
For a full rundown of telehealth billing codes, see our telehealth CPT codes cheat sheet.
Place of Service 11: In-Office Sessions
POS 11 (Office) is the workhorse code for in-person therapy. CMS defines it as a location, other than a hospital or other facility, where a health professional routinely provides diagnosis and treatment on an outpatient basis.
Translation: if the client is sitting across from you in your office, it's POS 11.
Common CPT codes you'll see with POS 11:
- 90832: 30-minute psychotherapy
- 90834: 45-minute psychotherapy
- 90837: 60-minute psychotherapy
- 90847: family therapy with the client present
- 90853: group therapy
Under Medicare, office-based services are generally paid at the non-facility rate, which is usually higher than the facility rate.
Place of Service 12: In-Person Home Visits
POS 12 (Home) is for when you go to the client. CMS defines it as a location, other than a hospital or other facility, where the patient receives care in a private residence.
POS 10 and POS 12 both involve the client's home, which is why they get mixed up:
- POS 10: telehealth, client at home, you're somewhere else
- POS 12: in person, and you're both in the client's home
Home visits can come up in home-based family therapy or with clients who can't easily get to an office. Coverage for in-home therapy varies a lot by payer and plan, so verify before billing POS 12, and document why a home visit was clinically appropriate.
Place of Service Codes List for Therapists
The full CMS place of service code list covers everything from pharmacies to ambulances. Here are the ones most relevant to mental health:
For most private practice therapists, POS 11, 10, and 02 will cover the vast majority of claims.
Medicare, Medicaid, and Commercial Payers: How the Rules Differ
Short version: the code definitions come from CMS, but each payer decides how to pay them and which modifiers they want. Don't assume one payer's rules apply to another.
Medicare
Medicare follows CMS's telehealth guidance directly. The key points from the CMS telehealth FAQ, updated February 2026:
- POS 02 and 10: use POS 02 for telehealth outside the client's home and POS 10 for telehealth in the client's home.
- Rates: since January 1, 2024, Medicare telehealth to clients at home is paid at the non-facility rate.
- Location: behavioral health telehealth has no geographic restrictions, so clients in rural and urban areas can get telehealth at home.
- Audio-only: audio-only is allowed for behavioral health telehealth.
- In-person visits: Medicare's in-person visit requirement for mental health telehealth doesn't kick in until after December 31, 2027. Clients who start telehealth before then won't need an in-person visit within 6 months beforehand, but they'll need one in-person visit every 12 months after 2027.
Medicare rules shift regularly, so check CMS's telehealth page or your Medicare Administrative Contractor before making big billing changes.
Medicaid
Medicaid is run by each state, so rules can vary. For example, MassHealth (Massachusetts Medicaid) requires:
- POS 02 for telehealth outside the client's home
- POS 10 for telehealth in the client's home
- Modifier 95 for counseling and therapy by audio and video
- Modifier 93 for audio-only services, and modifier FQ for counseling and therapy provided by audio only
Other states may handle it differently, and states update their rules over time. Your state Medicaid provider manual and bulletins are the source of truth.
Commercial Payers
Commercial insurers generally use the CMS code definitions, but their policies on modifiers, audio-only coverage, and home visits can be different from Medicare's. Some ask for modifier 95 on video sessions.
The safest habit: look up the current telehealth policy for each payer you bill often, usually in the provider portal. If you call, jot down the rep's name, the date, and a reference number.
How Place of Service Codes Affect Reimbursement
Payers often pay two different rates for the same service:
- Non-facility rate: usually higher. It applies when you're covering the overhead yourself, like in your own office.
- Facility rate: usually lower. It applies when a facility (like a hospital) covers the overhead.
For Medicare:
- POS 11 (office): non-facility rate
- POS 10 (telehealth at home): non-facility rate, since 2024
- POS 02 (telehealth elsewhere): facility rate
So if you've been defaulting to POS 02 for clients who are actually home, you might be getting paid less than you should on Medicare claims. Commercial payers set their own fee schedules, so check your contracts for how they handle this.
What Happens If You Use the Wrong Place of Service Code
A wrong POS code usually leads to one of two things:
- Denial: the claim gets rejected, often because the POS code doesn't line up with the modifier or the payer's policy. Our guide to insurance claim denials walks through how to handle these.
- Underpayment: the claim goes through but at the wrong rate. These are sneakier since everything looks fine.
The fix is usually a corrected claim (often sent as a replacement claim) with the right POS code and a reference to the original claim number. Every payer has a timely filing limit for corrections, so the sooner you catch it, the better.
To catch problems early, pull a few telehealth claims every so often and compare the POS codes to your session notes. If the note says "client at home" and the claim says 02, you've found something to fix.
Edge Cases: Hybrid Sessions and Group Practices
Hybrid sessions. There's no official "hybrid" POS code. If a session starts in the office and ends on video, check your payer's policy and document exactly what happened. When in doubt, call the payer and note the answer.
Group practices. POS codes should match where each session actually happened, which may not be the practice's main address. Many billing systems set a default POS for everyone, so review each clinician's settings, especially for anyone doing telehealth.
Keeping POS codes, CPT codes, and modifiers straight across every payer is a lot. Blueprint helps therapists spend less time on admin and more time with clients. See how Blueprint works.
For more billing basics, check out our mental health billing guide and mental health CPT codes list.
Place of Service Codes FAQ
What is the place of service code for telehealth therapy?
Use POS 10 if the client is at home and POS 02 if they're somewhere else. The client's location decides the code, not yours.
What is POS 02 vs. POS 10?
Both are telehealth codes. POS 10 is for clients at home, and POS 02 is for clients anywhere else. For Medicare, POS 10 is paid at the higher non-facility rate, while POS 02 is paid at the facility rate.
What is place of service 11?
POS 11 is the code for an office. Therapists use it for in-person sessions in their practice office.
What are POS 31, 32, and 23?
POS 31 is a skilled nursing facility, POS 32 is a nursing facility, and POS 23 is a hospital emergency room. Most private practice therapists won't use these often, but they come up if you provide services in those settings.
Do Medicare and commercial insurance use the same place of service codes?
They use the same CMS code definitions, but payment rules and modifier requirements can differ. Always check each payer's current policy.
What happens if I use the wrong place of service code?
The claim may be denied or paid at the wrong rate. Most mistakes can be fixed with a corrected claim before the payer's timely filing deadline.
