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Physician billing for procedures performed in an ASC

Physicians and practitioners performing services in Medicare-participating ambulatory surgical centers (ASCs) are reporting an incorrect place of service (POS) code. Services billed with the incorrect place of service could result in a claim denial or rejection.

The correct POS for physicians and practitioners who perform services in Medicare-participating ASCs is POS 24 (freestanding facility, other than a physician's office, where surgical and diagnostic services are provided on an ambulatory basis).

Do not report POS 11 (office), unless the physician has an office at the same physical location as the ASC, which meets all other requirements including the “distinct entity” criteria in the CMS Publication 100-07, State Operations Manual, Appendix L. This precludes the ASC and an adjacent physician office from being open at the same time.

ASC is any distinct entity operating exclusively for providing surgical services to patients not requiring hospitalization, and in which the expected duration of services would not exceed 24 hours following admission.

The entity must have an agreement with CMS to participate in Medicare as an ASC, and meet the conditions in the CMS Publication 100-04, Medicare Claims Processing Manual, Chapter 14.

Under the Medicare physician fee schedule (MPFS), some procedures have separate rates for physicians’ services when provided in facility and non-facility settings. The ASC payment does not include the professional services of the physician, the physician bills separately.

Physician services include the services of anesthesiologists:

  • Administration of anesthesia
  • Supervision of administration of anesthesia
  • Patients’ recovery from anesthesia

Physician services include any routine pre- or post-operative services, such as:

  • Office visits
  • Consultations
  • Diagnostic tests
  • Removing stitches
  • Changing dressings
  • Other services which the individual physician usually performs

The MAC pays the facility fee from the MPFS to the physician. The facility fee is for services performed in a facility other than the physician’s office and is typically less than the non-facility fee for services performed in the physician’s office.

For more information on physician billing requirements in an ASC, please review the CMS Publication 100-04, Claims Processing Manual, Chapter 12, Sections 20.4.2 and 90.3.