POS 11 vs POS 22
Place of Service 11 is a physician office. POS 22 is an on-campus hospital outpatient department. Choice affects MPFS payment under the site-of-service differential.
Last reviewed May 24, 2026
Side by side
POS 11 (Office)
Location, other than a hospital, skilled nursing facility, military treatment facility, community health center, or other facility, where the health professional routinely provides health examinations, diagnosis, and treatment.
POS 11- Full MPFS non-facility payment.
- Practice owns or leases the location; no facility claim filed for the encounter.
POS 22 (On-Campus Hospital Outpatient)
A portion of a hospital's main campus that provides diagnostic, therapeutic, and rehabilitation services to sick or injured persons who do not require hospitalization.
POS 22- MPFS facility payment (reduced from non-facility).
- Hospital separately bills facility fee under OPPS.
- POS 19 is the off-campus analog (different payment under site-neutral payment).
When to use POS 11 (Office)
- Encounter at a physician-owned or leased office not affiliated with a hospital.
When to use POS 22 (On-Campus Hospital Outpatient)
- Encounter at a hospital-owned outpatient clinic located on the main hospital campus.
Common mistakes
- Using POS 11 at a provider-based clinic — Medicare overpays, then recoups in audit.
- Mixing up POS 22 (on-campus) and POS 19 (off-campus) — payment differs under site-neutral rules.
- Not disclosing the facility fee to the patient when clinic is provider-based.
Sources
- CMS — Place of Service Code Sethttps://www.cms.gov/medicare/coding-billing/place-of-service-codes
- CMS — Site-of-Service Differential (MPFS)https://www.cms.gov/medicare/medicare-fee-for-service-payment/physicianfeesched
Related
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Open ask d3 →D3rx is a healthcare-billing and compliance research aid maintained by D3rx Inc. Articles are drafted by an LLM (Anthropic Claude) against primary HHS, OCR, CMS, eCFR, NIST, and state-regulator publications, and reviewed for restraint and source fidelity by the D3rx team.
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This comparison is a research aid for billing and compliance staff. It does not provide legal, medical, or financial advice and does not replace counsel. References cited link to primary sources at CMS, HHS, OCR, eCFR, NIST, and the relevant payer or state regulator. Last reviewed May 24, 2026.