POS 11 vs POS 22 essentials
POS 11 (Office) — services rendered in a physician's office, freestanding clinic, or non-facility setting. POS 22 (On-Campus Outpatient Hospital) — services rendered in an outpatient department of a hospital located on the hospital's main campus. Same CPT, different reimbursement: POS 11 pays the higher non-facility physician rate but no separate facility fee; POS 22 pays the lower facility physician rate plus a separate facility fee billed by the hospital. POS 19 covers off-campus hospital outpatient. POS 02 and POS 10 cover telehealth.
- POS 11 = office, non-facility rate, no facility fee
- POS 22 = on-campus outpatient hospital, facility rate + facility fee
- POS 02 = telehealth other than home
- POS 10 = telehealth in patient home
Place of Service Codes: POS 11 vs POS 22 and the Family
By MedPrecision Editorial Team · Published
Place of Service codes determine which fee schedule applies to a claim and what facility-related rules govern the payment. POS 11 (office) and POS 22 (on-campus outpatient hospital) reimburse differently for the same CPT — typically Medicare pays the office a higher physician fee but the hospital outpatient department also receives a separate facility fee, while POS 11 carries no facility fee but a higher physician rate. Understanding which POS applies and why matters for both compliance and reimbursement.
What Place of Service Codes Are
Place of Service (POS) codes are the two-digit codes on a CMS-1500 claim (Box 24B) or 837P transaction (Loop 2300 CLM05-1) that identify where the service was rendered. The codes are maintained by CMS and the National Uniform Claim Committee and are published on the CMS website. Each POS code corresponds to a specific facility type with associated rules — the office vs facility distinction affects the physician fee schedule applied, telehealth POS codes affect coverage and the requirement for the rendering provider to be in a specific location, and certain POS codes (emergency department, ambulance) trigger specific coverage rules. The POS code is one of the most heavily edited fields in claim adjudication; a POS that doesn't match the rendering provider's enrolled locations or the procedure type produces denials.
POS 11 (Office)
POS 11 is the code for services rendered in a physician's office, freestanding clinic, or non-facility setting. The Medicare physician fee schedule pays the 'non-facility' rate for services with POS 11 — which is higher than the facility rate because the practice expense component covers the office overhead. There is no separate facility fee billed for services in POS 11; the practice's overhead is built into the non-facility physician rate. POS 11 is the default for most physician office encounters, urgent care visits in freestanding clinics, and procedures performed in office-based settings. Practices that own and operate their office space, employ their staff, and bear the practice expenses bill POS 11.
POS 22 (On-Campus Outpatient Hospital)
POS 22 is for services rendered in an outpatient department of a hospital located on the hospital's main campus. The Medicare physician fee schedule pays the 'facility' rate for services with POS 22 — which is lower than the non-facility rate because the practice expense component is reduced. The hospital separately bills its facility fee under the Hospital Outpatient Prospective Payment System (OPPS), which covers the facility overhead, equipment, and supplies. Total Medicare payment for the same CPT in POS 22 (physician facility rate + hospital OPPS facility fee) is typically higher than POS 11, but the payment is split between the physician and the hospital. Provider-based clinics affiliated with hospitals on the hospital's main campus typically bill POS 22; the question of whether a clinic qualifies as 'on the hospital's main campus' is governed by 42 CFR 413.65 and CMS guidance.
POS 19 (Off-Campus Outpatient Hospital)
POS 19 was created in 2016 to identify hospital outpatient services rendered in off-campus locations — provider-based clinics not located on the hospital's main campus. The distinction matters because Section 603 of the Bipartisan Budget Act of 2015 limited reimbursement for new off-campus provider-based departments to a site-neutral rate (matching the physician fee schedule rather than the OPPS facility rate). Existing off-campus provider-based clinics ('grandfathered' departments) retained the higher OPPS rate; new off-campus departments after November 2, 2015 receive the site-neutral rate. POS 19 distinguishes these new off-campus departments from POS 22 (on-campus, full OPPS rate). The site-neutral rate adjustment was one of the more significant CMS payment policy changes in recent years and is a frequent source of payer-provider rate dispute.
POS 02 and POS 10 (Telehealth)
POS 02 (Telehealth Provided Other Than In Patient's Home) and POS 10 (Telehealth Provided in Patient's Home) are the telehealth POS codes. POS 02 was the original telehealth POS introduced before COVID-19; POS 10 was added in January 2022 to distinguish home-based telehealth specifically. Coverage rules during and after the public health emergency have shifted multiple times — Medicare's permanent telehealth flexibilities established by the 2024 Physician Fee Schedule rule continue to allow most telehealth services through 2024 and beyond, though some provisions are subject to expiration without congressional action. The choice between POS 02 and POS 10 depends on where the patient was during the encounter — at home for POS 10, at a different qualifying location for POS 02. Many commercial payers have aligned with the Medicare POS structure, but coverage rules vary. Telehealth reimbursement parity with in-person services is established by state law in some states and by payer policy in others.
Common POS Errors
Five POS error patterns produce denials. First, billing POS 11 for services rendered in a hospital outpatient department or hospital-based clinic — produces both a denial of the physician claim (wrong fee schedule) and a payment dispute with the hospital that bills the facility fee for the same encounter. Second, billing POS 22 for services in an off-campus location that qualifies as POS 19 — under-payment if the off-campus department is paid at the site-neutral rate rather than full OPPS. Third, billing POS 02 telehealth when the patient was at home (should be POS 10) — produces denials with some payers that have tightened POS audit logic. Fourth, billing POS 23 (emergency department) for services that don't qualify as ED encounters — produces audit triggers. Fifth, mismatched POS and rendering provider enrollment — billing POS for a location where the provider isn't enrolled with the payer.
Modifier 26 and TC for Split-Billing
When a procedure has both a professional component (the physician's interpretation work) and a technical component (the equipment, supplies, technician labor), the billing splits accordingly. Modifier 26 (Professional Component) identifies the physician's interpretation portion. Modifier TC (Technical Component) identifies the technical portion. Some procedures (X-rays, ultrasounds, laboratory tests) are commonly split-billed when the technical work happens at one location (a hospital, a freestanding imaging center) and the interpretation happens at another (a physician's office or a remote reading service). The POS on each component reflects where that specific component was performed — the technical component POS reflects where the equipment is; the professional component POS reflects where the physician interpreted. Coordinating POS across split billing is one of the more complex billing scenarios and a frequent source of denial when handled incorrectly.
Common Questions
Common questions about place of service codes: pos 11 vs pos 22 (and the others that matter).
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Get a Free Billing Audit arrow_forwardWhat is the difference between POS 11 and POS 22?
POS 11 (Office) is for services rendered in a physician's office, freestanding clinic, or non-facility setting. POS 22 (On-Campus Outpatient Hospital) is for services rendered in an outpatient department of a hospital on the hospital's main campus. Medicare pays the 'non-facility' physician rate for POS 11 and no separate facility fee — the practice's overhead is built into the higher physician rate. Medicare pays the lower 'facility' physician rate for POS 22 plus a separate facility fee billed by the hospital under the OPPS. Total Medicare payment for the same CPT in POS 22 is typically higher than POS 11, but split between the physician and the hospital. The choice of POS is determined by where the service was actually rendered and which entity bears the practice expense — practices that own and operate their office bill POS 11; provider-based clinics affiliated with on-campus hospital outpatient departments bill POS 22.
What is POS 19 and when does it apply?
POS 19 (Off-Campus Outpatient Hospital) was created in 2016 to identify hospital outpatient services rendered in off-campus provider-based clinics — locations not on the hospital's main campus. The distinction matters because Section 603 of the Bipartisan Budget Act of 2015 limited reimbursement for new off-campus provider-based departments (those established after November 2, 2015) to a site-neutral rate matching the physician fee schedule, rather than the higher OPPS rate paid to on-campus departments. Existing off-campus departments grandfathered before November 2, 2015 retained the higher OPPS rate. POS 19 distinguishes the new off-campus departments from POS 22 on-campus. Practices billing in hospital-affiliated off-campus clinics need to know which category their location falls in, because the reimbursement difference is meaningful and the wrong POS produces under- or over-payment.
What POS code do I use for telehealth?
POS 02 (Telehealth Provided Other Than In Patient's Home) is for telehealth services where the patient is at a non-home location during the encounter — for example, an originating site at another clinical facility. POS 10 (Telehealth Provided in Patient's Home) is for telehealth services where the patient is at home. POS 10 was added in January 2022 to distinguish home-based telehealth from other telehealth specifically. The choice is based on where the patient was during the encounter, not where the rendering provider was. Medicare's permanent telehealth flexibilities established by the 2024 Physician Fee Schedule rule continue most telehealth coverage with the appropriate POS, though some specific provisions face expiration without congressional action. Commercial payers have largely aligned with the Medicare POS structure but coverage rules and reimbursement parity vary by payer and by state.
What happens if I bill the wrong POS?
The wrong POS produces several possible outcomes depending on the specific error. Mismatched POS with the rendering provider's enrollment (billing POS for a location where the provider isn't enrolled with the payer) produces a denial. Wrong POS that produces an under-payment may simply be paid at the wrong rate without explicit denial — for example, billing POS 22 instead of POS 19 when the practice is in a site-neutral off-campus department results in under-payment. Wrong POS that produces an over-payment is recoverable on audit; the payer will recoup the overpayment plus possibly interest. Wrong POS for telehealth (billing POS 02 when patient was at home and the payer requires POS 10) produces denials with payers that have tightened POS audit logic. The defensible practice is to map each rendering location to its correct POS in the practice management system and configure the system to apply the POS automatically based on the encounter location.
Do I need a separate POS for each rendering location?
Yes — each rendering location has a specific POS that reflects the facility type. A practice operating multiple offices, clinics, and hospital-affiliated locations should map each location to its correct POS in the practice management system. The mapping should be configured at the location level so that encounters at each location automatically apply the correct POS to claims. Practices that manually apply POS at coding time (rather than configuring it at the location) introduce errors, particularly for providers who rotate across multiple locations. Common mapping errors include classifying a freestanding clinic as POS 22 when it should be POS 11 (no hospital affiliation), or classifying a hospital-affiliated clinic as POS 11 when it should be POS 19 or POS 22. Annual review of POS configuration as the practice opens or relocates locations prevents the mapping from drifting out of accuracy.
How does POS affect reimbursement?
POS determines which Medicare physician fee schedule rate applies to the claim. The non-facility rate (paid for POS 11 office and similar settings) is higher than the facility rate (paid for POS 22, POS 19, POS 23 ED, POS 21 inpatient, and other facility settings). The difference between non-facility and facility rates varies by CPT code but is typically 10-30% of the physician payment. The total Medicare payment also depends on whether a facility fee is billed separately — for POS 22 and POS 19 (when grandfathered), the hospital bills a facility fee under OPPS for the facility's portion of the encounter. For POS 11, no facility fee is separately billed. The total Medicare payment for the same CPT in POS 22 (physician facility rate + hospital OPPS) is typically higher than POS 11 (physician non-facility rate alone), but the payment splits between two billing entities. Commercial payers generally follow similar split-payment structures, with rates negotiated by contract.
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