In medical billing, the Place of Service (POS) code is crucial to the claim submission process. These two-digit codes specify the precise location where healthcare services were rendered on forms like the CMS-1500. Both CMS and private payers depend on POS codes to determine how claims are classified, reimbursed, and processed.
Even by mistake, using the wrong POS code can lead to claim denials, underpayments, and compliance issues. Two of the most frequently confused codes are POS 11 (Office) and POS 22 (On-Campus Outpatient Hospital). Although they both apply to outpatient services, they represent distinct billing environments and carry different administrative and financial implications.
Platforms like MedVirtual help streamline the claim submission process by enabling healthcare providers to better manage POS accuracy, reduce administrative burdens, and ensure proper coding.
To help billing professionals and healthcare providers navigate these differences confidently, the table below outlines the five key distinctions between POS 11 and POS 22 in the context of the modern medical billing and claim submission process.
The 5 Key Differences Between POS 11 and POS 22 in Billing
In medical billing, using the correct Place of Service (POS) code isn’t just a technical detail; it’s a critical factor that affects reimbursement, claim acceptance, and overall revenue cycle efficiency. Two commonly used POS codes, POS 11 (Office) and POS 22 (On-Campus Outpatient Hospital), may seem interchangeable but are fundamentally different in how services are billed and reimbursed.
To help healthcare providers, billing teams, and practice managers stay compliant and financially optimized, here's a side-by-side breakdown of the five key differences between POS 11 and POS 22.
Comparison Table: POS 11 vs. POS 22 in Medical Billing Process
1. Service Location
POS 11 refers to healthcare services provided in a physician-owned office or clinic, where the provider controls the setting. In contrast, POS 22 applies to services delivered in an outpatient department located on a hospital’s main campus, typically managed under the hospital's infrastructure.
2. Ownership & Billing
In POS 11 scenarios, the facility is independently owned, and the provider submits a single professional claim. With POS 22, the setting is hospital-owned, requiring separate claims: one from the provider for professional services and one from the hospital for facility charges.
3. Reimbursement
POS 11 typically results in higher professional reimbursement, since the provider bears all operational costs. On the other hand, POS 22 usually yields lower professional reimbursement, as the hospital bills separately for facility usage, reducing the provider’s payment.
4. Claim Complexity
Claims submitted under POS 11 are generally simpler, involving fewer administrative steps and billing layers. POS 22 introduces greater complexity, requiring dual billing and close coordination between the provider and the hospital to ensure accuracy and compliance.
5. Patient Costs
Patients treated under POS 11 often face lower out-of-pocket expenses, as there are no separate facility fees. Under POS 22, patient costs may be higher due to the addition of facility charges submitted by the hospital, which can increase coinsurance or copayments.
By understanding the five key differences outlined above, providers and billing teams can improve claim accuracy, reduce administrative burdens, and enhance patient trust through greater transparency.
Always confirm the service setting, ownership, and billing structure before coding. In medical billing, accuracy is profit.
System-Level Benefits of POS 11 and POS 22
While the primary differences between POS 11 and POS 22 revolve around billing structure and reimbursement, each code also aligns with specific system-level advantages that affect how practices manage operations, technology, and patient flow.
POS 11 – Office (Non-Facility Setting)
- Streamlined EHR and billing system integration for faster onboarding and simplified workflow configuration
- User-friendly interface ideal for smaller, independently run clinics
- Direct control over payment processing, scheduling, and reporting tools
- Reduced administrative burden thanks to single-entity billing and claim management
- Greater flexibility in choosing third-party applications for practice management
POS 22 – On-Campus Outpatient Hospital (Facility Setting)
- Built-in compatibility with hospital-grade infrastructure and centralized systems
- Advanced reporting and analytics dashboards to track KPIs across departments
- Integrated patient verification and auto-claim processing for high-volume outpatient care
- Multi-location scalability, ideal for healthcare systems with various service points
- Centralized employee management tools to streamline staffing, scheduling, and compliance
These system-level considerations can help healthcare providers choose not only the correct billing code, but also the most effective operational model for their practice or facility.
Introduction to Place of Service (POS) Codes
Simply put, when physicians and healthcare service providers treat patients, they do so in facilities like hospitals, clinics, medical offices, and private practices. Unlike large government or corporate organizations, these are small, community-based facilities. In medical billing, these locations are designated using specific codes known as Place of Service or POS codes.
Place of Service or POS codes are two-digit identifiers that inform insurance companies of the settings where healthcare services were rendered. This enables both government and private insurers to determine the appropriate reimbursement amount for the services provided.
There are two categories of POS Codes. These are referred to as:
- Facility POS Codes
- Non-Facility POS Codes
Let's talk about these categories briefly to give you an idea of their significance in claim submission process and to get appropriate reimbursement.
Facility POS Codes
Facility POS Codes refer to specific codes that highlight patient treatments in settings like hospitals, nursing homes, and skilled nursing centers. These codes are crucial and required to track patient care, ensure accurate records, and correct payment against submitted claims. These codes include:
- Inpatient Hospital (21)
- Outpatient Hospital (22)
- Emergency Room-Hospital (23)
- Urgent Care Facility (20)
- Skilled Nursing Facility (31)
- Hospice Facility (32)
- Ambulatory Surgical Center (24)
Non-Facility POS Codes
These codes categorize the treatments provided in facilities and centers other than hospitals. So, if you're visiting your family doctor for a routine checkup, seek a specialist's expertise for a treatment procedure, or want to receive physical therapy from a nearby clinic, the services fall under the umbrella of non-facility POS Codes. These codes include:
- Office (11)
- Home (12)
- School (03)
- Independent Clinic (49)
There are two main types of POS codes: POS 11 and POS 22. POS 11 refers to a doctor's office, clinic, or practice. When you visit a doctor's office or clinic, they will include POS 11 on the medical bill to indicate the exact location of the care provided.
What is POS 11 in Medical Billing?
According to CMS, ‘Place of Service (POS) 11 refers to 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 health professionals routinely provide health examinations, diagnoses, and treatments for illness or injury on an ambulatory basis.
Here's a scenario explaining the inclusion of the right place of service code for professional claims.
When it comes to ‘On Campus – Outpatient,' if the hospital owns the space or employs all healthcare providers working there, the claim must include POS 22. In this scenario, reimbursement for the care provider is typically lower because the hospital assumes full operational responsibility and submits claims for facility use.
Conversely, if a physician's office operates independently within the hospital premises, the provider should use POS 11 on the claim. Two critical factors determine this classification:
- The physician or healthcare provider is responsible for paying rent and staff salaries from their own revenue.
- The physician's practice maintains a separate Tax Identification Number (TIN) distinct from the hospital's for submitting professional claims.
Advantages of POS 11 in Medical Billing
POS 11, which represents services delivered in a physician-owned office or clinic, offers several operational and billing advantages:
- Simplified billing process: Claims submitted with POS 11 typically involve only the professional component, reducing administrative complexity.
- Greater control over operations: Providers fully control staffing, scheduling, and billing practices, streamlining workflow.
- Fewer billing errors: Using POS 11 accurately minimizes discrepancies that can lead to claim denials or audits.
- Efficient reimbursement cycles: Clean, single-entity claims are processed faster, often leading to quicker payments.
- Operational flexibility: Independent practices using POS 11 can implement tools like real-time insurance verification or digital intake forms to enhance revenue cycle efficiency.
While POS 11 doesn’t directly determine software features, its use within independently run clinics often correlates with leaner, more agile systems and fewer administrative barriers.
What is POS 22 in Medical Billing?
POS 22 points towards delivering on-campus services in an outpatient setting, hospital, clinic, or practice. Due to its special features and options for recording the services provided, a large majority of doctors, clinics, and practices use POS 22 before submitting the medical bill.
According to CMS, ‘On campus here means a portion of a hospital's main campus which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.'
In case a physician doesn't recommend formal hospitalization for the patient, or if the patient treatment can be performed outside the hospital's premises, then the patient will be referred to as an outpatient. Also, if the facility is situated within 250 yards of the hospital, it would be designated as ‘hospital outpatient unit.'
Off campus means a part of a hospital's provider-based department located away to provide therapeutic, diagnostic and rehabilitation services to patients who aren't advised hospitalization. Inpatient means a facility, other than psychiatric, that deals with therapeutic, diagnostic and rehabilitation services by or under supervision of a doctor to those admitted for multiple conditions.
Advantages of POS 22 in Medical Billing
POS 22 is used when healthcare services are provided in a hospital’s outpatient department located on its main campus. While it comes with increased billing complexity, it also supports specific operational models:
- Supports hospital-affiliated outpatient care: POS 22 allows hospitals and affiliated providers to bill separately for professional and facility services, creating transparency in cost allocation.
- Aligns with centralized infrastructure: It is ideal for organizations operating under a single tax ID and with integrated staffing, scheduling, and administration.
- Standardized workflows: Enables large healthcare networks to implement consistent billing and compliance practices across hospital outpatient departments.
- Accommodates high-volume environments: POS 22 settings often serve larger patient volumes with robust systems for claim tracking and payer coordination.
- Facilitates coordination between clinical and billing teams when integrated within a hospital-based system.
While POS 22 may increase administrative requirements, it’s well-suited for large healthcare networks prioritizing centralized oversight, uniform processes, and facility-level revenue management.
Take Control of Your Medical Billing with the Right POS Code
In medical billing, getting the Place of Service (POS) code correct is essential for accurate claims and full reimbursement. Each POS code, whether for outpatient care or a facility, informs insurers exactly where the care was provided, which directly influences how claims are processed and approved. By providing the correct POS code, healthcare providers can reduce denials and prevent delays, resulting in smoother billing and faster payments.
Solutions like MedVirtual can further enhance billing operations by allowing healthcare providers to streamline billing procedures, improve patient account management, and ensure appropriate reimbursement through integrated, virtual medical billing platforms.
Frequently Asked Questions (FAQ)
What is the difference between POS 22 and 11?
POS 11 refers to services provided in a physician's office or independent clinic, representing a non-facility setting with typically higher reimbursement rates. POS 22 indicates services rendered in an on-campus outpatient hospital setting, where the hospital owns the facility and bills separately for facility charges, often resulting in lower professional reimbursement.
What is a POS 22?
POS 22 is a Place of Service code used in medical billing to denote outpatient services provided on a hospital's main campus, such as diagnostic, therapeutic, or rehabilitation services, without formal inpatient admission.
What is POS 11 in medical billing?
POS 11 is the Place of Service code used to identify medical services delivered in a physician's office or independent clinic setting, outside of hospital or facility environments.
What is the point of service code 22?
Point of Service code 22 indicates that healthcare services were provided in an outpatient hospital setting located on the hospital's main campus, typically involving hospital-owned facilities.
What is code 22 in medical billing?
Code 22 in medical billing refers to the outpatient hospital setting on the hospital campus, used to bill services provided in hospital outpatient departments.
What is POS II?
POS II is a common misinterpretation or typographical error for POS 11; the correct code for physician office services is POS 11.
Is POS 22 considered facility or non-facility?
POS 22 is considered a facility code because it represents services provided in hospital outpatient departments or outpatient hospital settings.
Can POS 22 be used for observation?
Yes, POS 22 can be used for observation services provided in an outpatient hospital setting on the hospital campus.
When to use GT modifier?
The GT modifier is used to indicate that a service was provided via interactive audio and video telecommunications systems (telehealth). It is applied when billing for telemedicine services to specify the mode of service delivery.
