5 Key Differences Between POS 11 vs POS 22 in Billing

In medical billing, Place of Service (POS) codes tell payers where a healthcare service was provided, helping them apply the appropriate billing and reimbursement rules. POS 11 and POS 22 identify different service settings on professional claims. The distinction affects how the service is reported and, under the MPFS, whether the facility or nonfacility rate applies.

This article explains what POS 11 and POS 22 mean under CMS’s Place of Service code set, the five key differences between them, and how to determine which code applies to a given claim.

What Is POS 11 in Medical Billing?

CMS defines Place of Service 11 (Office) as a location, other than a hospital, skilled nursing facility (SNF), military treatment facility, community health center, State or local public health clinic, or intermediate care facility (ICF), where a health professional routinely provides health examinations, diagnosis, and treatment of illness or injury on an ambulatory basis.

Under the MPFS facility and non-facility payment designations, POS 11 is a non-facility setting.

When Is POS 11 Used?

• A patient receives an ambulatory examination, diagnosis, or treatment at a physician’s private office.
• A provider furnishes services at a location that meets CMS’s Office definition and does not fall under a hospital, SNF, or the other excluded settings named in that definition.
• Per CMS’s special considerations for outpatient hospital departments, a physician uses POS 11 when services occur in a separately maintained physician office space in a hospital or on a hospital campus, provided that space is not a provider-based department of the hospital under 42 CFR 413.65.

For example, a physician evaluates a patient at a location that meets CMS’s Office definition. POS 11 applies when the location and the applicable payer’s requirements are both satisfied.

What Should a Biller Verify for POS 11?

• The actual location where the face-to-face service occurred
• Whether that location fits CMS’s Office definition, rather than a hospital, SNF, or other excluded setting
• Whether Item 24B on the claim matches the service location, as instructed in CMS’s Medicare Claims Processing Manual
• The applicable payer’s specific requirements, since CMS directs providers to check individual payers for reimbursement policies

What Is POS 22 in Medical Billing?

CMS defines Place of Service 22 (On Campus-Outpatient Hospital) as a portion of a hospital’s main campus that provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.

Under the MPFS payment designations, POS 22 is a facility setting.

POS 22 is used when:

• A patient receives outpatient diagnostic, therapeutic, or rehabilitation services in a hospital department on the hospital’s main campus.
• Per CMS’s special considerations for services furnished to registered outpatients, a physician furnishing services to a hospital outpatient, including in a provider-based hospital outpatient department, reports POS 22 (or POS 19 for an off-campus department) at a minimum, regardless of where the face-to-face encounter occurs.
• CMS’s guidance on diagnostic test interpretations gives an example where a beneficiary receives an MRI on an outpatient hospital campus; the physician who interprets that MRI from an office location still reports POS 22, since the code reflects the setting where the beneficiary received the technical component.

POS 11 vs POS 22: 5 Key Differences

The distinctions below are drawn from CMS’s Place of Service code definitions and the Medicare Claims Processing Manual’s payment instructions. 

1. Service Location

POS 11 identifies an office location as CMS defines it, while POS 22 identifies a portion of a hospital’s main campus. In medical coding, the POS code generally reflects the actual setting where the beneficiary receives the face-to-face service.

For example, CMS’s manual notes that when a physician’s face-to-face encounter occurs in the office, the correct POS code is generally 11. When that same physician furnishes services to a registered hospital outpatient, CMS instructs the physician to report POS 19 or 22 at a minimum, regardless of where the face-to-face encounter actually takes place.

2. Facility vs. Non-Facility Payment Classification

CMS’s manual states that, under the MPFS, some procedures have separate rates for physician services depending on facility or nonfacility setting, and CMS publishes both rates in the Medicare Physician Fee Schedule Database.

Attribute	POS 11	POS 22
CMS POS name	Office	On Campus-Outpatient Hospital
Setting	Office	Portion of a hospital’s main campus
MPFS payment designation	Nonfacility	Facility

CMS’s manual lists Office (POS 11) among settings paid at the nonfacility rate, and Outpatient Hospital-On Campus (POS 22) among settings paid at the facility rate.

3. Claim Reporting Requirements

CMS instructs that Item 24B of the CMS-1500 claim form requires the appropriate POS code to identify the setting for each service line. For services provided to a registered hospital outpatient, CMS instructs physicians and practitioners to report POS 19 or POS 22, as applicable, regardless of where the face-to-face encounter actually occurs. 

4. Reimbursement and Payment Methodology

CMS’s manual states that the rate paid under the MPFS, facility or nonfacility, is determined by the POS code identifying the setting where the beneficiary received the face-to-face encounter.

Factor	POS 11	POS 22
Setting	Office	On Campus-Outpatient Hospital
MPFS payment rate	Nonfacility rate	Facility rate
Determined by	POS code reported on the claim	POS code reported on the claim

CMS ties this payment distinction to the POS code reported, and separately instructs providers to check with individual payers for the reimbursement policies that apply under each payer’s own rules.

5. Hospital Outpatient vs. Office Billing Context

CMS’s special considerations for outpatient hospital departments state that physicians who perform services in a hospital outpatient department must use, at a minimum, POS 19 or POS 22, unless the physician maintains a separately maintained office space in the hospital or on the hospital campus.

Attribute	POS 11	POS 22
Reflects	A separately maintained office setting	A hospital outpatient department on the main campus
Applies when	The location is not a provider-based hospital department	The location is a provider-based hospital outpatient department on-campus

How to Determine the Correct POS Code

These steps help you check the service location carefully so the POS code matches the requirements for your claim.

Step 1: Identify Where the Service Was Provided

CMS’s manual states that, for MPFS payment purposes, the POS code generally reflects the actual setting where the beneficiary receives the face-to-face service.

Step 2: Determine Whether the Setting Matches POS 11 or POS 22

Compare the location against CMS’s definitions: an Office location under POS 11, or a portion of a hospital’s main campus under POS 22.

Step 3: If It Is Hospital Outpatient Care, Determine the Applicable Hospital POS

CMS distinguishes on-campus outpatient hospital departments (POS 22) from off-campus outpatient hospital departments (POS 19), based on the campus definition at 42 CFR 413.65(a)(2).

Step 4: Check the Applicable Medicare or Payer Guidance

CMS’s POS code database instructs providers to check with individual payers for their reimbursement policies.

Step 5: Verify the POS Before Claim Submission

CMS’s manual instructs Medicare Administrative Contractors to return a claim as unprocessable if it lacks a valid POS code in Item 24B, or if the POS code is inconsistent with the procedure billed.

Common POS 11 and POS 22 Coding Errors

Several POS 11 and POS 22 errors can create claim-processing or payment issues. CMS guidance identifies specific requirements that help prevent these errors.

Mistake 1: Using POS 11 for Hospital Outpatient Care

CMS instructs physicians providing services in a hospital outpatient department to report POS 19 or POS 22 as applicable. An exception applies when the office meets CMS’s requirements for a separately maintained, non-provider-based office.

Mistake 2: Using POS 22 for Every Hospital Service

POS 22 is specifically for an on-campus outpatient hospital setting. CMS also identifies other hospital-related POS codes, including POS 23 for an emergency room and POS 24 for an ambulatory surgical center.

Mistake 3: Confusing POS 19 and POS 22

POS 19 identifies an off-campus outpatient hospital setting, while POS 22 identifies an on-campus outpatient hospital setting. The applicable code depends on the location and CMS’s POS definitions.

Mistake 4: Using POS 11 for a Hospital Outpatient Department

CMS allows POS 11 in certain office situations on or near a hospital campus when the office meets the applicable requirements and is not a provider-based department.

Mistake 5: Ignoring Payer-Specific POS Rules

CMS advises providers to check individual payers for their reimbursement policies. Medicare requirements should not automatically be treated as the requirements of every commercial payer.

Mistake 6: Reporting an Invalid POS Code

CMS claim-processing guidance addresses claims with missing, invalid, or inconsistent POS information. Such claims may require correction before Medicare can process them.

How Incorrect POS Reporting Can Affect Payment

CMS’s Medicare Claims Processing Manual states that the POS code determines whether the facility or nonfacility rate is paid under the MPFS. Because of this, an incorrect POS entry can change which payment rate applies to a claim.

CMS’s manual also instructs Medicare Administrative Contractors to return a claim as unprocessable when the POS code is missing, invalid, or inconsistent with the billed procedure code, using remark code M77. 

In that circumstance, an incorrect POS code can create avoidable claim and payment issues. A medical billing audit can help identify POS coding errors, location mismatches, and other billing concerns before they affect future claims. Reviewing these issues with a billing professional gives your practice a clearer path to correct the problem and strengthen POS coding accuracy. 

How Practices Can Improve POS Coding Accuracy

A few checks can help keep the POS code aligned with CMS requirements and the payer’s rules.

• Verify the service location: Match the POS code to the setting where the service was provided. CMS identifies the setting through the POS code set.
• Check the current CMS code set: Review the applicable POS definition before assigning the code. CMS maintains and updates the national POS code set.
• Review payer requirements: CMS advises providers to check individual payers for reimbursement policies related to POS codes.
• Verify the claim before submission: For CMS-1500 claims, Item 24B requires the appropriate POS code for each service line.
• Ask the right payer or MAC when unclear: CMS directs Medicare billing and coding questions to the applicable Medicare Administrative Contractor and questions for private insurance to the individual payer.
  
  

Conclusion

POS 11 and POS 22 serve different billing settings, so checking the location carefully can help you report the code that fits the service. Keeping the definitions and payment rules clear also makes claim review easier. When a situation is unclear, use the current CMS guidance and check the payer’s requirements before submitting the claim. This gives the billing team a clear basis for choosing the POS code and handling questions that may come up during claim processing.

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