Section 12. CPST Billing Requirements

Section 12 should be revised to include clear Place of Service (POS) billing guidance for CPST. The proposed regs expand services into natural, community-based settings (which is a positive change!). But they do not explain how providers should determine the correct POS when services occur in multiple settings during the same encounter or when billable activities, such as treatment planning or care coordination, occur from the provider's office.

Without clear guidance, providers and MCOs will interpret POS requirements differently. This creates unnecessary audit risk, recoupments, and administrative burden; even when services are delivered appropriately.

A standard DMAS POS billing policy should be established and applied consistently across FFS + MCOs, so providers have one billing standard to follow, and we’re not left guessing.