Modifier PO

20.6.11 - Modifier PO (Rev. 11897; Issued:03-10-23; Effective:04-01-23; Implementation:04-03-23) PO: Excepted service provided at an off-campus, outpatient, provider-based department of a hospital As described in the CY 2015 OPPS/ASC final rule (79 FR 66910 through 66914), CMS established HCPCS modifier PO to describe excepted service provided at an off-campus, outpatient, provider-based department of a hospital. This modifier should be reported with every HCPCS code for all outpatient hospital items and services furnished in an excepted 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. Note that reporting of this modifier was voluntary for CY 2015, but is required beginning January 1, 2016. We note that, beginning in CY 2019, we finalized a policy to pay for clinic visits (G0463) billed at excepted off-campus provider-based departments (departments that bill modifier “PO” on their claim lines) at the PFS-equivalent amount. We phased-in this policy in over a two-year period. Specifically, half of the total 60-percent payment reduction, a 30- percent reduction, was applied in CY 2019. Consequently, these departments were paid 70 percent of the OPPS rate (100 percent of the OPPS rate minus the 30-percent payment reduction that applies in CY 2019) for the clinic visit. In CY 2020, the two-year phase-in was completed. The PFS-equivalent rate for CY 2020 and subsequent years is 40 percent of the proposed OPPS payment (that is, 60 percent less than the proposed OPPS rate). Off-campus provider-based departments should not report both the PO and PN modifiers on the same claim line. However, if services reported on a claim reflect items and services furnished from both an excepted and a nonexcepted off-campus PBD of the hospital, the PO modifier should be used on the excepted claim lines and the PN modifier should be used on the nonexcepted claim lines. Neither the PO nor the PN modifier is to be reported by the following hospital departments: • A dedicated emergency department as defined in existing regulations at 42 CFR 489.24(b); • A PBD that is “on the campus,” or within 250 yards, of the hospital or a remote location of the hospital as defined under 42 CFR 413.65.