In 2015, CMS introduced the voluntary reporting of the PO modifier. This modifier is for “services, procedures, and/or surgeries furnished at off-campus, provider-based outpatient departments” for each service provided at these locations.
CMS has said that it hopes to use the PO modifier to show the frequency and types of services performed in off-campus, provider-based outpatient departments. At this time, the modifier has no impact on payment.
As of January 1, 2016 the use of the PO modifier changes from voluntary to required.
What do the regulations say?
20.6.11 – Use of HCPCS Modifier – PO
(Rev.3280, Issued: 06-05-15, Effective: 07-01-15, Implementation: 07-06-15)
Effective January 1, 2015, the definition of modifier -PO is “Services, procedures, and/or surgeries furnished at off-campus provider-based outpatient departments.” This modifier is to be reported with every HCPCS code for all outpatient hospital items and services furnished in an off-campus provider-based department of a hospital. See 42 CFR 413.65(a)(2) for a definition of “campus.”
This modifier should not be reported for remote locations of a hospital (defined at 42 CFR 413.65(a)(2)), satellite facilities of a hospital (defined at 42 CFR 412.22(h)), or for services furnished in an emergency department.
Reporting of this modifier is voluntary for CY 2015; reporting of this modifier is required beginning January 1, 2016.
So what does all this mean?
Organizations should determine whether they have received the designation of off-campus provider-based organization. If you do have this designation, then PO modifiers must be added to each of your charges submitted by this location. Each organization also needs to determine if its billing system can accept/accommodate the modifier. Organizations should contact their MACs for assistance to determine their clinics’ designation.