Guide to Place of Service (POS) Codes 11 and 22 in Medical Billing

Every day, healthcare providers deliver care in different settings—sometimes in a private office or a hospital outpatient center. But when it comes to getting paid for those services, the difference between these places isn’t just physical—it’s found in two small numbers on a claim: POS 11 and POS 22.

These two-digit Place of Service (POS) codes indicate to insurance companies where the care was provided. This simple detail can significantly impact how much you’re reimbursed, the modifiers you need, and whether your claim is approved or denied. Using the incorrect code can result in lost revenue or costly delays.

In this guide, we’ll explain everything you need to know about POS 11 and 22—from what they mean and how to use them correctly to real-life examples, payer rules, common mistakes, and best practices that can help keep your billing clean and compliant.

POS Codes in Medical Billing 

In the world of medical billing, accuracy is everything. Even the smallest detail—like a two-digit number—can determine whether a claim is paid or denied. That’s where Place of Service (POS) codes come in.

What Are POS Codes?

POS codes are two-digit numbers submitted on healthcare claims to indicate where a service was provided. They tell the insurance payer exactly where the patient received care—was it in private practice, a hospital outpatient clinic, or perhaps through telehealth?

POS codes are like postal codes for your service: they pinpoint the location so that the payer can assign the correct reimbursement rate based on that setting.

Imagine a cardiologist who performs an EKG (Electrocardiogram) in two different places:

• Scenario 1: At their private clinic
• Scenario 2: At a hospital outpatient department where they also practice

Now, here’s the catch. Although the procedure remains the same, the Place of Service does not. If the provider mistakenly bills the hospital EKG as if it were done in the office (POS 11 instead of POS 22), the claim may be flagged, and reimbursement could be reduced, denied, or recouped later.

Common POS Code Examples:

POS Code	Description	Typical Setting
11	Office	Private medical practice or leased clinic space
22	Outpatient Hospital	Hospital-owned clinic or outpatient department
02	Telehealth Provided Other Than in the Patient’s Home	Remote care during the public health emergency
10	Telehealth Provided in Patient’s Home	For services rendered while the patient is at home

POS 11 in Medical Billing (Office Settings)

If you’re working in or managing a private medical practice, chances are you’re using POS 11 more than any other code. It’s the default go-to for services rendered in a typical physician-owned office or clinic, but it’s essential to understand when and how to use it correctly.

What is POS Code 11?

POS 11 indicates that the service took place in a physician’s office—a location that’s independently owned or leased and not operated by a hospital. This includes:

• Solo practices
• Group medical offices
• Independent clinics
• Specialist offices (e.g., dermatology, cardiology, psychiatry)

In short, if your practice pays for its own space, staff, utilities, and medical equipment and is not part of a hospital or health system, then POS 11 is likely the correct code.

How to Use POS 11 Correctly

Use POS 11 on your claims only when the service occurs in an office that:

• It is not hospital-owned or operated
• Is it independently owned or leased
• It has its own administrative and billing structure
• Provides care in a non-facility setting

If your clinic is located on a hospital campus and independently leased and operated, POS 11 still applies. The key is ownership and management, not geography.

POS 11 in Claim Submission

Correctly assigning POS 11 ensures that the physician’s work and the cost of delivering care are appropriately reimbursed, which is essential for maintaining a healthy revenue cycle.

Services Billed Under POS 11:

• Preventive care and wellness visits (Annual physicals, immunizations)
• Follow-up visits for ongoing conditions like hypertension or diabetes
• Chronic disease management (COPD, asthma, heart disease)
• In-office diagnostics (e.g., spirometry, electrocardiograms, urinalysis)
• Minor procedures (e.g., skin biopsies, joint injections, cryotherapy)

Example: A family medicine doctor sees a patient for a diabetes follow-up and performs an in-office foot exam and blood pressure check. This visit is billed under POS 11, and all services are coded accordingly.

POS 11 Reimbursement Structure

One of the significant benefits of POS 11 is that providers typically receive higher reimbursement compared to facility settings.

Here’s why:

POS 11 qualifies for the “non-facility” Medicare Physician Fee Schedule rate

That rate includes payment for:

• Professional Component (PC) – the provider’s expertise and time
• Practice Expense (PE) – the cost of operating the office, including rent, support staff, medical equipment, and supplies

This full-rate payment is designed to offset private practices’ operational burden, unlike hospital settings, where those overhead costs are billed separately.

 Remember, the same CPT code (e.g., 99214) reimburses more in POS 11 than in POS 22 due to the added “practice expense” payment.

Coding and Modifier Considerations for POS 11

Billing under POS 11 is generally straightforward, but there are still a few best practices to keep in mind:

• No Modifier Required (In Most Cases): When billing global services (e.g., a complete procedure done by one provider), you usually don’t need to add a modifier.
• If you’re billing only part of a service (such as interpretation only for an imaging study), modifier 26 may apply.
• Use In-Office CPT Codes: Select CPT codes that accurately reflect services typically provided in an office setting.
• No TC/26 Split Needed for In-House Services: If you own the diagnostic equipment and perform services on-site, you can bill the global code—there is no need to split it with TC/26.

Let’s say a cardiologist is working in a private, independently owned clinic. She performs an EKG (CPT 93000) for a patient with chest discomfort. Because the clinic owns the equipment and she interprets the results herself:

She bills POS 11

• Uses CPT 93000 (global code—includes both performance and interpretation)
• No modifier is needed

As a result, she receives full reimbursement for her time and use of the EKG equipment, as it was performed in a non-facility setting.

When NOT to Use POS 11

• If your office is owned or managed by a hospital
• If the service is performed in a hospital outpatient department
• If you’re providing telehealth from a remote location (this often requires POS 10 or 02 with modifier 95)

POS 22 in Medical Billing

When healthcare services are performed in a hospital-owned outpatient department, the correct designation is POS Code 22. It may seem like just a setting detail, but in billing, location determines everything—from how you bill to how much you’re paid.

What is POS Code 22?

Place of Service 22 is used for services rendered in an outpatient facility owned and operated by a hospital. Even if a provider is not directly employed by the hospital, as long as the service occurs on hospital property or in a hospital-managed outpatient clinic, POS 22 must be used.

How POS 22 Differs from Office Settings

Here’s the crucial distinction: when you bill under POS 11, you’re billing as an independent practice that incurs all costs associated with it. Under POS 22, the hospital shares the overhead, equipment, and staffing burden, and that changes the payment structure.

Even if the same doctor performs the same service, reimbursement may differ drastically based on the place of service.

Key Difference from POS 11: 

• POS 22 = hospital-owned location
• POS 11 = independently owned or private medical office

Services Billed Under POS 22

POS 22 applies to a wide range of hospital-based outpatient services, such as:

• Outpatient surgeries (e.g., cataract removal, colonoscopy)
• Diagnostic imaging (e.g., CT scans, MRIs, X-rays)
• Infusion therapies (e.g., chemotherapy, IV antibiotics)
• Hospital-based wound care or physical rehab
• Specialist consults conducted at hospital outpatient clinics

Reimbursement Structure: Facility vs. Non-Facility

POS 22 billing follows the facility rate structure, which splits reimbursement between:

• Professional Component (PC) — Paid to the provider
• Technical Component (TC) — Billed separately by the hospital

Providers typically receive lower reimbursement for the same CPT code than they would under POS 11.

Example Comparison:

Setting	CPT Code 93000 (EKG)	Reimbursement
POS 11	Includes PC + TC	Higher total payment to a physician
POS 22	Only PC (modifier 26)	Lower payment; hospital bills TC separately

This division reflects the shared responsibility, where providers bring expertise while hospitals provide the physical resources and infrastructure.

Coding and Modifier for POS 22

When billing in POS 22, using the correct CPT modifiers is crucial to ensure accurate payment and avoid payer pushback.

Modifier 26 – Professional Component

Use this when billing for interpretation or professional services only, especially for imaging or lab tests done in the facility.

Modifier TC – Technical Component

The hospital typically bills this to reflect the use of equipment, staff, and supplies.

In many outpatient hospital settings, the physician and the hospital submit separate claims for the same service:

Split Billing

• Physician bills CPT code + Modifier 26 + POS 22
• Hospital bills have the same CPT code + Modifier TC + POS 22

Tip: Forgetting to add modifier 26 can lead to denials or underpayments, as payers assume you’re trying to bill for both components.

 Dr. Jackson, a radiologist, interprets a chest X-ray taken at a hospital’s outpatient imaging center. Here’s how her billing should look:

• Place of Service: POS 22 (because it’s hospital-based)
• CPT Code: 71045 (chest X-ray, single view)
• Modifier: 26 (for interpretation only)

By applying modifier 26, she receives payment only for the interpretation, not for using the X-ray machine or the technician’s time—the hospital bills separately for those.

When Not to Use POS 22

Avoid using POS 22 if:

• The facility is independently owned (even if it’s across from a hospital)
• Services are performed in a private office suite, not managed by the hospital
• You’re providing care via telehealth (which often uses POS 10 or 02)
• The facility does not meet CMS criteria for a hospital outpatient department

Insurance Coverage and Payer-Specific Rules

Correctly using Place of Service (POS) codes 11 and 22 is more than just a billing detail—it’s essential for accurate payment and avoiding denials. Different payers, including Medicare, Medicaid, and commercial insurers, have unique guidelines and expectations regarding POS coding. With the addition of telehealth coverage, it’s easy to see why practices must stay vigilant.

Let’s break down what you need to know by insurance type and use case.

Medicare Guidelines for POS 11 and 22

When billing to Medicare, accuracy with POS codes is critical, because they influence:

Reimbursement rate (facility vs. non-facility)

Required CPT modifiers (like 26 or TC)

Auditing risk (wrong POS = red flag)

POS 11 – Office

• Use when services are rendered in a privately owned or leased office space
• Medicare pays at the non-facility rate, which includes:
• Professional services (physician’s work)
• Practice expenses (rent, staff, supplies)
• No modifier is needed unless you’re separating professional and technical components.

POS 22 – Outpatient Hospital

• Use when services occur in a hospital-owned outpatient facility
• Medicare pays only for the professional component
• The hospital bills separately for technical costs
• Modifier 26 is usually required to indicate that you’re billing for interpretation or professional service only

CMS Warning: Billing POS 11 for services provided in a hospital-owned clinic—even if the provider is independent—can result in payment recoupments or audit penalties.

POS 11 and 22 Billing and Coding Errors

Even the most experienced billing teams make mistakes—but when it comes to Place of Service (POS) codes, minor errors can lead to claim rejections, underpayments, or worse—payer audits. Understanding standard POS 11 and POS 22 coding errors can help you correct workflows and safeguard your revenue cycle.

Let’s break down the most frequent mistakes—and how to avoid them.

Common POS 11 Errors

POS 11 (Physician’s Office) is meant for independent, non-hospital-owned locations. Here are typical missteps:

• Used for Hospital-Owned Outpatient Clinics: If a provider rents space or operates independently within a hospital-affiliated outpatient facility, using POS 11 is incorrect. This should be POS 22 instead.
• Incorrect POS for Telehealth Visits: Using POS 11 for virtual services without the correct telehealth modifier (95) or without considering POS 10 (for home-based care) can result in denials or down-coding.
• Location Not Supported by Documentation: If documentation doesn’t clearly state where the service was provided, payers may default to denying or flagging the claim during audits.

Always ensure that SOAP notes or visit records match the billed POS code. If they are unclear, assume they may need to be reviewed manually.

Common POS 22 Errors

POS 22 (Outpatient Hospital Setting) requires careful documentation and coordination with the facility’s coding. Here’s where things go wrong:

• Used for Freestanding/Independent Clinics: If a clinic isn’t hospital-owned, even if it’s located next to or on hospital grounds, POS 22 isn’t applicable. Use POS 11 in that case.
• Missing TC/26 Modifiers on Diagnostics: A physician billing diagnostic services done in a hospital outpatient setting must use modifier 26 to denote the professional component. Failing to consider this can result in duplicate billing or denied claims.
• Applied to Services Done Outside a Hospital System: Services performed in a private imaging center, urgent care, or mobile clinic should never be coded with POS 22—even if the equipment used is hospital-grade.

Best Practices for Accurate & Compliant POS Code Usage

Regarding Place of Service (POS) coding, accuracy isn’t just about getting paid — it’s about staying compliant, avoiding audits, and ensuring your documentation tells the same story as your claims. POS codes can make or break a clean claim in neurology, where services may span office visits, hospital consults, telehealth, diagnostics, and outpatient procedures.

Here’s how to get it right — consistently.

Verifying Service Location

• Cross-reference the physical address against your location master list to determine the correct Place of service.
• Confirm facility ownership (hospital-owned vs. independent) before assigning POS 11 or 22.
• Document the actual place of service in the provider’s note (e.g., “Hospital outpatient suite”).

EHR & Documentation Alignment

• Configure EHR templates to automatically fill in the correct POS based on visit type and location.
• Review EHR POS defaults quarterly and update them when adding new service sites.
• Include POS verification as a mandatory step in the chart review process before submitting claims.

 Billing Staff Training

• Conduct monthly 15-minute huddles focused on real-world POS scenarios.
• Use payer-specific cheat sheets to illustrate the differences in POS coding.
• Provide visual guides showing when to use POS 02 vs. POS 10 for telehealth.

Modifier & CPT Accuracy

• Use Modifier 26 for interpretation-only services in POS 22 settings.
• Add Modifier 95 for synchronous telehealth services along with the correct POS.
• Avoid billing full global CPT codes when only the technical or professional component was provided.

Telehealth Compliance

• Verify the patient’s physical location during each telehealth session and document it clearly.
• Match POS 02 (non-home) or POS 10 (home) based on where the patient was during service.
• Validate telehealth billing rules per payer monthly, especially for Modifier 95 usage.

Audits & Consistency Checks

• Audit a sample of 10 high-volume claims monthly for POS and modifier accuracy.
• Cross-check claims for the same patient and date to ensure consistent provider POS.
• Flag any POS-mismatched claims during denial reviews to identify EHR or process errors.

Documentation Alignment

• Ensure provider notes clearly state the service location (e.g., “seen in hospital-affiliated neurology suite”).
• Include time, location, and reason for service, especially for time-based or telehealth codes.
• Conduct periodic documentation-to-claim audits to verify the consistency of POS and modifiers.

Telehealth Policy Monitoring

• Subscribe to CMS and payer bulletins to stay informed about the evolving POS and telehealth rules.
• Maintain an internal matrix comparing POS and modifier requirements across major payers.
• Designate a team lead to track telehealth compliance and communicate updates to staff.

Coordination with Front Office & Clinical Teams

• Train schedulers to ask and log the correct service location during appointment setup.
• Use clear, appointment-type naming (e.g., “Telehealth Visit – Patient at Home”) in your electronic medical record (EMR).
• Ensure the front desk confirms patient location at check-in for accurate POS coding.

Payer and Compliance Integration

• Create payer-specific cheat sheets showing POS, Modifier, and documentation requirements.
• Monitor payer denials related to incorrect POS and adjust internal workflows accordingly.
• Collaborate with compliance and coding leads to ensure POS policies meet federal and state standards.

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• Automate POS defaults based on location types
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Conclusion

POS codes may seem small, but they carry significant consequences. By correctly assigning POS 11 or 22, using accurate modifiers, and aligning with payer expectations, you can:

• Ensure timely and full reimbursement
• Avoid costly billing errors
• Stay compliant with Medicare and commercial payer rules

Your place of service tells a story—make sure it’s right.

Frequently Asked Questions (FAQs)

Can I use POS 11 if I’m a contractor working at a hospital outpatient clinic?

No. Even if you’re not a hospital employee, you must bill under POS 22 if the facility is hospital-owned.

What happens if I use the wrong POS code?

Incorrect POS codes can result in:

• Denied claims
• Underpayment
• Payer audits or recoupments

Can telehealth services use POS 11 or 22?

Yes, but it depends on the payer. Use modifier 95 and refer to each insurer’s telehealth policy. Medicare often pays more when POS 11 is used correctly for virtual care.

How often should we audit our POS coding?

Ideally, conduct quarterly audits to identify systemic errors and ensure compliance across all locations, especially in mixed ownership environments.

Need expert help with POS coding and claim accuracy?

At ANR Medical Billing, we specialize in ensuring clean, compliant billing for healthcare providers in Connecticut and across the United States. From POS 11 and 22 compliance to full-spectrum medical billing and coding services, we help you maximize reimbursement and avoid costly denials.

👉 Contact ANR Medical Billing today to streamline your practice’s revenue cycle — and get paid faster!