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POS 34: Hospice — Billing Rules, GV/GW Modifiers & Common Denials

Where POS 34 applies, who actually bills what once a patient elects hospice, and the CO-B9 denial that blindsides practices when a patient enrolls without telling them.

What Is POS 34?

Place of Service code 34 identifies a hospice facility — "a facility, other than a patient's home, in which palliative and supportive care for terminally ill patients and their families are provided." Use POS 34 when care is delivered at a freestanding hospice house or inpatient hospice unit. When hospice care is delivered in the patient's own home, the correct code is POS 12 (Home); when the patient lives in a nursing facility and receives hospice there, the nursing facility code (POS 31/POS 32) applies. POS follows where the patient physically was — not who employs the clinician.

The bigger story: the moment a Medicare patient elects hospice, billing rules change for every provider who touches them — not just the hospice. Miss the election, and your routine claims start denying with CO-B9.

Who Bills What After a Hospice Election

The Denial That Comes With It: CO-B9

The classic hospice billing surprise: a practice bills a routine visit, and the remit comes back CO-B9 — "patient is enrolled in a hospice." The patient elected hospice and nobody updated the chart. The fix depends on the truth of the encounter: if the service related to the terminal illness and your physician is the designated attending, rebill with GV. If it was unrelated care, rebill with GW and documentation supporting the separation. If your physician was neither the attending nor treating something unrelated, the payment path runs through the hospice — contact them before writing anything off. Prevention beats all of it: check hospice election status in eligibility verification (Medicare eligibility responses flag it) for every Medicare patient, every visit.

POS 34 Claim Checklist

  1. Confirm the site: freestanding hospice facility → POS 34; patient's home → POS 12; nursing home resident → POS 31/32. Site-of-service affects payment rates, so payers audit mismatches
  2. Confirm hospice election dates in eligibility — elections and revocations change mid-month, and claims spanning the boundary need splitting
  3. Append GV or GW correctly — a claim with POS 34 and no hospice modifier from a non-hospice provider is a near-guaranteed denial
  4. Match diagnosis to modifier: GW claims should carry diagnoses clearly distinct from the terminal condition
  5. For Medicare Advantage patients: traditional Medicare pays hospice-related claims even for MA enrollees (through 2026''s evolving carve-in models — verify current plan rules), so know which payer gets which claim

The Four Hospice Levels of Care (and Why Billers Should Care)

Medicare's hospice benefit pays the hospice a per-diem at one of four levels: routine home care (the default, wherever the patient resides), continuous home care (crisis-level nursing at home), general inpatient care (symptom management that can't be handled at home — often the level in play at a POS 34 facility), and inpatient respite care (short stays to relieve the family caregiver). Why this matters outside the hospice's own billing office: the level of care explains where the patient physically is, which drives your POS code, and it tells you whether a facility stay is hospice-run (bill the hospice or use GV/GW rules) versus a regular admission that happens to involve a hospice patient. When a claim spans a level-of-care change — say home care shifting to general inpatient mid-week — split billing by date range keeps every line consistent with the place of service on file.

Frequently Asked Questions

What's the difference between POS 34 and POS 12 for hospice patients?
Location, not enrollment. Hospice care at a hospice facility is POS 34; hospice care in the patient's own home is POS 12. The hospice election status travels with the patient — the POS code travels with the address.
What are the GV and GW modifiers?
GV = service by the patient's designated attending physician who is not employed by the hospice, related to the terminal illness. GW = service unrelated to the terminal condition. One of them belongs on nearly every Part B claim for a hospice-enrolled patient.
Why did my claim deny with CO-B9?
The patient is enrolled in hospice and your claim didn't account for it. Rebill with GV (attending, terminal-illness care) or GW (unrelated care) as the facts support — or route the claim to the hospice if your service was part of the hospice plan of care.
Can a nurse practitioner be the hospice attending?
Yes — Medicare allows an NP (or PA) to serve as the designated attending and bill with GV, though they cannot certify the terminal illness. The certification still requires a physician.

Related: POS 31 — skilled nursing facility · POS 32 — nursing facility · POS 12 — home · Denial code library · Full POS library

Not sure this is the right code? Use the POS decision tree — two questions, and it shows the facility vs non-facility pay impact.

Hassan Raza AwanReviewed by Hassan Raza Awan, Founder — 4+ years of hands-on U.S. medical billing experience. General billing information — verify against current CMS guidance and your payer contracts.

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