POS 11 vs. POS 22: Which Place of Service Code Should You Bill?
Bill POS 11 for services in a freestanding physician office and POS 22 for services in an outpatient department on a hospital’s main campus (off-campus hospital departments use POS 19).
POS 11 pays the higher non-facility rate because the practice covers its own overhead, while POS 22 pays the lower facility rate because the hospital bills that overhead separately.
What is the difference between POS 11 and POS 22?
Place of service code 11 is an office outside any hospital. Place of service code 22 is a hospital outpatient department on the main campus, where patients get care without being admitted. Both come from the CMS place of service code set and go in Box 24B of the CMS-1500 or the 837P.
POS 11 | POS 22 | |
CMS name | Office | On Campus-Outpatient Hospital |
Typical setting | Private practice or independent therapy clinic | Hospital outpatient clinic on the main campus |
Medicare rate for the provider | Non-facility (higher) | Facility (lower) |
Claims per visit | One professional claim | Professional claim plus hospital facility claim |
POS 19 is the twin people forget: the same hospital outpatient setting, just off the main campus. For the full code list, see our guide to place of service codes in medical billing.
When should you bill POS 11 or POS 22?
The office vs. hospital outpatient POS code choice follows the patient's hospital registration and the location's setup, not how the room looks. Under Medicare's POS 22 billing rules, a registered hospital outpatient gets at least POS 19 or POS 22, wherever the face-to-face visit happened.
Independent office. An ABA or speech therapy clinic in a rented suite, run by the practice, bills POS 11.
Hospital outpatient department. A developmental pediatrics clinic in the hospital's main building registers each child as a hospital outpatient. Bill POS 22 and the hospital sends its own facility claim.
Hospital-owned clinic. This is where most mistakes happen. A provider-based department that registers hospital outpatients bills POS 22 on campus or POS 19 off campus. A hospital-owned practice run as a freestanding physician office, with no facility claim, stays POS 11.
The trap: the same exam room can switch from POS 11 to POS 22 or 19 after a hospital buys the practice, with nothing visible changing. Get the location's provider-based status in writing before building it in your system.
How do POS 11 and POS 22 affect reimbursement?
In POS 11 vs 22 reimbursement, the office code usually pays the provider more. The Medicare Physician Fee Schedule's non-facility rate includes office costs like rent and staff, while POS 22 triggers the lower facility rate because the hospital bills those costs separately.
CPT 99213, 2026 Medicare national rate | Paid to the provider |
POS 11, office (non-facility) | $95.19 |
POS 22, hospital outpatient (facility) | $57.45, plus a separate hospital payment |
That's $37.74 less per visit, about 40%, before local adjustments. The gap changes by CPT code and locality and many commercial and Medicaid plans set their own rules.
The hospital's half of a POS 22 visit goes on the UB-04 with revenue codes, not POS codes. Our explainer on revenue codes in medical billing walks through that facility claim.
What errors cause POS 11 and POS 22 claim problems?
Most POS code billing errors start in the setup, not at coding. An HHS-OIG audit found Medicare contractors potentially overpaid physicians about $33.4 million from January 2010 to September 2012 for facility services billed as office services. It blamed weak billing controls.
Outdated system defaults: the location profile sends POS 11 even on hospital clinic days.
Mismatched location records: the claim's service address doesn't match the payer's file.
Enrollment gaps: some payers want the provider enrolled at that exact site, so provider credentialing gaps show up as location denials.
CPT-to-POS conflicts: some codes aren't payable in some settings.
A denial refuses the line, often with CARC 5, CARC 58 or RARC M77. An underpayment pays at the wrong rate with no denial code, so a POS 22 that should've been POS 11 can sit in posted payments for months. The reverse, POS 11 on a hospital visit, becomes an overpayment you must return.
How can you correct a wrong POS 11 or POS 22 code?
Change the code only when the record proves the right setting.
Verify the encounter. Check the visit note, the scheduled location and the patient's hospital registration that day.
Read the remittance. Find the line's reason codes and compare the allowed amount to the right fee schedule.
Correct it the payer's way. Medicare Part B fixes a place of service through a clerical error reopening, generally within one year of the initial determination. Most commercial payers want a replacement claim (frequency code 7) with the original claim number.
Appeal when you billed it right. Send the visit note and proof of location with the payer's reconsideration or appeal request.
Our steps to fix place of service code denials go deeper on reason codes and deadlines.
POS 11 vs. POS 22 FAQs
Does POS 22 always pay less than POS 11?
No. Under Medicare, POS 22 usually pays the provider less because it triggers the facility rate, but the gap varies by CPT code, locality and payer. For CPT 99213 in 2026, the national gap is $37.74 per visit. Commercial contracts set their own rates.
Should a hospital-owned clinic use POS 11 or POS 22?
It depends on how the hospital runs it. A provider-based department that registers patients as hospital outpatients uses POS 22 on the main campus or POS 19 off campus. A hospital-owned practice run as a freestanding physician office, with no hospital facility claim, uses POS 11.
Can an incorrect POS code cause a claim denial?
Yes. A POS code that conflicts with the CPT code, payer policy or the provider's enrolled location can be denied with CARC 5, CARC 58 or RARC M77. A wrong POS can also pay at the wrong rate, causing an underpayment or overpayment instead.
Bill POS 11 vs. POS 22 from the record, not the room
The POS 11 vs POS 22 decision takes seconds when each location is set up right and months to unwind when it isn't. Audit every service location and confirm registration rules with each hospital partner. Then check payments against the fee schedule every month.
If POS denials or short payments keep coming back, Pacemave's denial management services team can trace them to the location setup and recover what's still within the filing window.
