Place of Service 2 vs 10 for Telehealth Therapy

Code	Where the client is	When to use it	Modifier	Effective date
POS 02	Somewhere other than the client’s home	The client receives telehealth at another permitted location, such as an office, shelter, or facility	95 for synchronous audio-video or 93 for synchronous audio-only, when the payer requires it	January 1, 2017
POS 10	The client’s home or another private residence	The client receives telehealth while physically at home	95 for synchronous audio-video or 93 for synchronous audio-only, when the payer requires it	January 1, 2022

The place-of-service code answers one question: where was the client physically located during the encounter? When a biller searches for place of service 2, that phrase refers to POS 02, telehealth provided somewhere other than the client’s home. It does not identify where you were sitting, and it does not replace the procedure code or a payer-required telehealth modifier. CMS defines both codes in its Place of Service Code Set. For the broader workflow around claims, documentation, and payer checks, see the insurance billing guide for therapy practices.

Educational resource for licensed US mental-health clinicians and billing staff. Payer policies, CMS guidance, CPT descriptors, and state telehealth rules change. Verify the current requirement for the payer, service, and date of service before submitting a claim. This guide is not legal, coding, licensure, or reimbursement advice.

How to choose POS 02 or POS 10

Ask the client where they were physically located when the session occurred. Use POS 10 if the answer is a private residence. Use POS 02 if the answer is another location. Record the location in the note and make sure the claim, note, and telehealth workflow use the same answer.

A client’s location can change from one visit to the next. Do not copy yesterday’s POS code into today’s claim without confirming the location for today’s encounter. If the client moved from home to an office, facility, or another permitted setting, the POS code may need to change even when the therapist, procedure code, and video platform stay the same.

POS 02: telehealth outside the client’s home

POS 02 means telehealth was provided somewhere other than the patient’s home. In plain language, place of service 2 is the location code to review when the client is elsewhere. The code can fit a session in another permitted setting when the client is not in a private residence. The client’s actual location still needs to be documented, because “not home” is not a substitute for a useful location record.

Do not use POS 02 simply because the therapist is working from an office. The code follows the client’s location. If the client is at home while you are in your office, POS 10 is the location code to review.

POS 10: telehealth in the client’s home

POS 10 means telehealth was provided while the patient was in the patient’s home. CMS added POS 10 to distinguish home-based telehealth from telehealth provided somewhere else. Use it when the client is in a private residence during the encounter, subject to the payer’s current policy.

The client’s home can be different from the address on file. Ask where the client is physically located for the session and document the answer rather than assuming the mailing address is the encounter location.

Match the place-of-service code to the delivery method

POS 02 and POS 10 identify location. They do not prove that the visit used live video. When a payer requires a delivery-method modifier, review the actual modality:

• Synchronous audio-video: Review modifier 95 when the payer requires it for the procedure code.
• Synchronous audio-only: Review modifier 93 when the payer covers the service and requires the modifier.
• In-person service: Do not use a telehealth POS code just because the appointment was scheduled through a telehealth platform.

CMS describes the federal Medicare telehealth billing path in its Medicare Claims Processing Manual, Chapter 12, section 190.6. Commercial payer rules can differ. Treat a payer’s modifier instruction as that payer’s rule, not as a universal rule for every claim.

Document the location before the claim

Use a short workflow that the clinician and biller can repeat:

1. Ask the client where they are physically located at the start of the session.
2. Confirm whether that location is a private residence or another setting.
3. Select POS 10 for a private residence or POS 02 for another location.
4. Record the client’s location and the synchronous modality in the clinical note.
5. Review the payer’s current rule for the procedure, POS code, and modifier.
6. Check that the claim and note agree before submission.

Do not turn the location field into a guess. If the client cannot confirm where they are, pause the billing workflow and resolve the location before selecting a POS code. If the client changes location during the encounter, document the event and ask the payer or a qualified biller how the claim should be handled.

A repeatable telehealth claim preflight

The checklist is a pre-submit control, not a substitute for the payer’s policy or the clinician’s documentation. If the payer requires a different modifier, POS pairing, or telehealth attestation for the service, follow that payer-specific instruction and retain the policy reference with the claim workflow.

Common POS 02 and POS 10 errors

Using the therapist’s location

A therapist may work from an office while the client is at home. That fact does not make the claim POS 02 or place of service 2. Review the client’s physical location, because POS 10 describes telehealth provided in the patient’s home.

Treating POS 10 as a modifier

POS 10 is a place-of-service code. It does not describe whether the session used video or audio only. Review the actual modality and the current payer requirement separately.

Carrying forward a copied code

A copied claim template can preserve yesterday’s POS code after a client changes location. Make the location question a session-day step, not only an intake field.

Making a Medicare rule universal

CMS Medicare guidance does not automatically control every commercial payer claim. Confirm the payer, procedure, date of service, and contract or policy before applying a familiar POS and modifier combination.

Letting the claim contradict the note

A POS 10 claim with a note that says the client was in an office needs correction before submission. Coding and documentation should tell the same story about the encounter.

How Emosapien supports the documentation handoff

Emosapien’s Scribe Agent can surface prompts for modality and client location while drafting a clinician-reviewed note. It does not choose a billing code or replace payer verification. The clinician confirms the encounter details, and the billing workflow applies the current payer rule before the claim goes out.

Download the telehealth billing checklist

The CPT 95 modifier telehealth billing checklist gives your practice a printable companion for the modifier, place-of-service, modality, and documentation checks. Use it beside this POS 02 versus POS 10 reference when your workflow covers both location selection and the claim-line modifier.

References

• Centers for Medicare & Medicaid Services. Place of Service Code Set.
• Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual, Chapter 12, section 190.6.
• Electronic Code of Federal Regulations. 42 C.F.R. § 410.78, Telehealth services.