5 Key Differences Between POS 11 and POS 22 in Billing
POS 11 identifies an office, while POS 22 identifies an on-campus outpatient hospital department. Under Medicare, POS 11 is generally associated with the nonfacility Physician Fee Schedule rate, while POS 22 is a facility setting for applicable professional services. The difference can affect professional payment, hospital billing, patient cost sharing, and whether a claim accurately reflects where and under what status the patient received care.
For billing teams, the safest approach is not to choose between POS 11 and POS 22 based on the building name alone. Patient registration status, provider-based status, the exact service location, and payer rules can all affect the correct code.
TABLE OF CONTENTS
| Billing question | POS 11 | POS 22 |
|---|---|---|
| CMS name | Office | On Campus-Outpatient Hospital |
| Setting | Nonhospital office setting | Hospital outpatient department on the hospital's main campus |
| Medicare PFS designation | Nonfacility for applicable physician services | Facility for applicable physician services |
| Professional claim POS | 11 | 22 |
| Separate hospital billing | Generally not part of an ordinary office encounter | Hospital outpatient charges may also apply |
| Patient cost effect | Usually office-based cost sharing, subject to plan terms | Hospital outpatient cost sharing can be higher |
| Closely related code | Other nonfacility POS codes may apply depending on setting | POS 19 applies to off-campus outpatient hospital departments |
POS 11 and POS 22 identify different outpatient settings
CMS defines POS 11, Office as a location other than a hospital, skilled nursing facility, military treatment facility, community health center, public health clinic, or intermediate care facility where a health professional routinely provides ambulatory examinations, diagnoses, and treatment.
CMS defines POS 22, On Campus-Outpatient Hospital as a portion of a hospital’s main campus that provides diagnostic, therapeutic, surgical, nonsurgical, or rehabilitation services to patients who do not require hospitalization.
Both can involve outpatient care. They do not describe the same billing setting.
That distinction becomes important because the POS code on the professional claim gives Medicare and other payers information about the setting in which the service was furnished.
Five differences that can change billing
1. POS 11 describes an office; POS 22 describes an on-campus hospital outpatient department
The first difference is the care setting itself.
POS 11 is appropriate for qualifying office services. A typical example is a physician seeing patients in an independently maintained medical office.
POS 22 applies to qualifying outpatient hospital services on the hospital’s main campus.
A common billing mistake is reducing this question to ownership. Hospital affiliation alone does not settle every case.
CMS instructions state that a physician who maintains separate office space in or on a hospital campus can use POS 11 when that office is not considered a provider-based department of the hospital. Conversely, services furnished to registered hospital outpatients generally require an appropriate outpatient hospital POS, such as POS 19 or POS 22.
For claim review, ask what the patient’s billing status and actual service setting were on the date of service, not simply whether the address was connected to a hospital.
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2. Medicare can apply different professional payment rates
For services paid under the Medicare Physician Fee Schedule, some procedures have separate facility and nonfacility rates.
CMS lists POS 22 as a facility setting and POS 11 as a nonfacility setting. The distinction reflects, in part, whether practice-expense resources such as clinical staff, supplies, and equipment are being accounted for through the physician payment or through a facility payment.
This is why a professional service may have a different Medicare payment amount when performed in an office instead of a hospital outpatient department.
It is still inaccurate to say that POS 11 always pays more.
CMS says the site-of-service differential applies to some procedures. It also identifies exceptions. For example, the professional component of diagnostic tests has the same facility and nonfacility payment rate regardless of the POS code reported on the claim.
Billing teams should therefore check the applicable fee schedule and payer policy for the actual CPT or HCPCS code rather than applying a blanket POS reimbursement assumption.
3. POS 22 can involve both professional and hospital outpatient charges
An ordinary POS 11 office claim generally represents the professional services and practice resources associated with that office encounter.
A hospital outpatient encounter works differently. The physician or practitioner may submit the professional component using the appropriate hospital outpatient POS, while the hospital bills for the institutional resources associated with the outpatient service when applicable.
That distinction helps explain why the Medicare Physician Fee Schedule uses the facility rate for applicable physician services furnished to hospital outpatients. CMS is avoiding payment of the same practice-expense resources through both the professional and facility sides of the encounter.
The precise billing structure varies by service, payer, provider arrangement, and hospital department. Billing staff should not assume that every POS 22 encounter produces an identical pair of charges.
4. POS selection depends on patient status and the actual billing setting
The POS code is not merely a description added after the rest of the claim is finished. It is a required claim element.
CMS instructs physicians and practitioners billing services under the Physician Fee Schedule to report the POS assigned to the setting where the patient received the face-to-face service. For registered hospital outpatients, CMS provides additional instructions for reporting an appropriate outpatient hospital POS.
This makes several details worth verifying before claim submission:
This makes several details worth verifying before claim submission:
- Was the patient registered as a hospital outpatient?
- Where did the service physically occur?
- Was the department provider-based?
- Was it on the hospital’s main campus or off campus?
- Was the service actually performed in a separately maintained physician office?
- Does the payer apply additional POS-specific billing instructions?
A single address can sometimes contain more than one billing environment. That is one reason an address lookup alone is not a reliable POS control.
5. The setting can affect what the patient owes
POS selection is not only a provider reimbursement issue.
Medicare states that a beneficiary may pay more for outpatient services received in a hospital outpatient setting than for the same care in a doctor’s office. Medicare beneficiaries also usually pay a hospital copayment for each hospital outpatient service, apart from certain services that do not carry that copayment.
That does not mean every patient with a POS 22 claim will owe more than a patient with POS 11.
The actual amount depends on factors such as coverage, the service performed, assignment, the type of facility, and the patient’s insurance arrangement. Commercial plans and Medicare Advantage plans can also apply their own benefit and network structures.
For billing and patient-service teams, the practical point is that the place of service may affect both claim payment and the patient’s financial experience.
A hospital address alone does not make a visit POS 22
One of the more useful CMS distinctions concerns physician offices located in or near hospitals.
CMS says POS 19 or POS 22 should generally be used for hospital outpatient departments, depending on whether the department is off campus or on campus. There is an important exception: if the physician maintains separate office space in or on the hospital campus and that space is not a provider-based department, CMS instructs the physician to use POS 11 for services actually performed in that office.
This means three situations that appear geographically similar can have different POS results:
- A separately maintained physician office that is not provider-based can support POS 11.
- A provider-based outpatient department on the hospital’s main campus can support POS 22.
- A qualifying off-campus hospital outpatient department can require POS 19.
Ownership, distance, signage, or a shared hospital address should not be used as the sole coding test.
POS 19 belongs in the same billing decision
POS 19 is Off Campus-Outpatient Hospital.
CMS introduced the distinction between POS 19 and POS 22 so professional claims could identify whether hospital outpatient services were furnished off campus or on campus. POS 22 now specifically refers to an on-campus outpatient hospital setting.
For billers, this creates a three-way distinction worth keeping clear:
| Situation | Likely POS category under CMS rules |
|---|---|
| Qualifying physician office | POS 11 |
| Off-campus hospital outpatient department | POS 19 |
| On-campus hospital outpatient department | POS 22 |
The final code still depends on the facts of the encounter and applicable payer instructions.
The POS code belongs in a specific professional claim field
On a paper CMS-1500 professional claim, the POS code belongs in Item 24B.
For electronic professional claims, CMS identifies Loop 2300 CLM05-1 or Loop 2400 SV105 as the relevant POS fields. The code identifies the setting for the item or service being billed.
That detail matters when a practice is troubleshooting claims.
If the correct POS exists in the scheduling system or EHR but maps incorrectly into Item 24B or the 837P transaction, the payer still receives the wrong setting. A useful POS audit should therefore check both the source data and the final claim output.
A repeatable claim review can reduce POS rework
A practical POS review starts before claim submission and continues through remittance analysis.
1. Confirm the patient’s status for the date of service.
Determine whether the patient was treated as an office patient, registered hospital outpatient, inpatient, or another status that changes the applicable POS.
2. Confirm the exact care setting.
Do not rely only on the organization name or street address. Identify the office, hospital department, emergency department, ASC, or other setting where the service occurred.
3. Verify provider-based status when hospital space is involved.
A physician office on a hospital campus is not automatically POS 22. CMS specifically recognizes separately maintained physician office space that is not a provider-based department.
4. Distinguish on-campus from off-campus hospital outpatient care.
Use the CMS definitions for POS 19 and POS 22 instead of treating every outpatient hospital service as POS 22.
5. Check the payer’s current instructions.
The national CMS code set provides the setting definitions, but CMS also advises providers to check individual payer reimbursement policies. Commercial payer edits and contractual rules may differ from Medicare.
6. Check the final claim output.
Confirm that the POS transmitted in Item 24B or the electronic claim matches the setting established during review.
7. Use denials and payment variances to find recurring mapping problems.
If the same location repeatedly produces POS-related denials, unexpected payment, or corrected claims, investigate the upstream location configuration instead of treating each claim as an isolated error.
Medicare telehealth generally uses POS 02 or POS 10
POS 11 and POS 22 should not automatically be carried over to Medicare telehealth claims.
CMS’s February 2026 telehealth guidance instructs physicians and practitioners to use:
- POS 02 when telehealth is provided and the patient is somewhere other than the patient’s home.
- POS 10 when the patient receives the telehealth service at home.
CMS also states that covered Medicare telehealth services reported with POS 10 are paid at the nonfacility Physician Fee Schedule rate under the applicable policy.
That distinction is especially useful for practices updating old billing rules or EHR mappings that were created under earlier telehealth policies.
Portiva can support the administrative billing workflow
POS accuracy depends on having the right information reach the claim at the right point in the billing process.
Portiva’s medical billing service supports claims submission, insurance verification, payer follow-up, denial management, payment posting, and related revenue cycle work. Portiva works alongside a healthcare organization’s existing processes while the practice retains clinical and management control.
For a practice managing services across office and hospital settings, that can include administrative support around claim preparation, identifying recurring denial patterns, following unresolved claims, and processing corrected submissions when appropriate.
Frequently Asked Questions:
Is POS 11 a facility or nonfacility setting?
For Medicare Physician Fee Schedule purposes, POS 11 is a nonfacility setting. CMS lists Office, POS 11, among the settings paid at the nonfacility rate when the service is subject to the facility and nonfacility payment distinction.
Is POS 22 a facility setting?
Yes. CMS identifies POS 22, On Campus-Outpatient Hospital, as a facility setting for applicable Physician Fee Schedule services.
Does POS 11 always reimburse more than POS 22?
Can an office located inside a hospital use POS 11?
When should POS 19 be considered instead of POS 22?
Where is POS reported on the CMS-1500 claim?
Does POS 22 always create a separate facility fee for the patient?
Should POS 11 be used for Medicare telehealth?
Need more billing capacity?
Need more billing capacity?
Practices working across office and hospital settings often have more to manage than POS selection alone. Claims still need to be prepared, submitted, followed, corrected when appropriate, posted, and reconciled.
Portiva provides administrative medical billing support across claims submission, insurance verification, claims follow-up, denial management, payment posting, and related revenue cycle tasks. The practice remains responsible for its clinical decisions, payer requirements, and coding oversight while Portiva supports assigned billing work.
For services involving POS 11, POS 19, POS 22, or other settings, always verify the facts of the encounter and the current requirements of the applicable payer before submitting the claim.
