Q&A: Update on modifiers -PN and -PO

Q. Is modifier -PN used instead of or in addition to modifier -PO in a non-excepted department? Do we still need to add modifier -PO in general?

A. Yes, you would still need to add modifier -PO to off-campus services, however, modifiers -PO and -PN would not apply to the same services. The modifier -PO requirement has not been removed, but its definition was change to include only “excepted” department services. Modifier -PN is used for “nonexcepted” departments. Start by asking yourself, is the department off-campus? If yes, then you can ask, is the department an “excepted” department? If yes, modifier -PO will likely apply. However, you have to be careful because there are some “excepted” department services that CMS has clarified you would not use the modifier -PO, such as therapy or lab when paid separately. If you are off-campus in a non-excepted department on the other hand modifier -PN would apply. CMS did not exempt services such as therapy and lab from application of modifier -PN. This means you would use -PN on those services if they are provided in a “nonexcepted” department even though you would not use -PO if they are provided in an “excepted” department.

Editor’s note: This question was answered by Kimberly Anderwood Hoy Baker, JD, CPC, director of Medicare and Compliance for HCPro, a division of BLR, in Middleton, Massachusetts.

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