Place of Service 11 indicates that the service was rendered in a physician’s office, but its relevance in medical billing isn’t limited to that pithy descriptor. For healthcare payments, the distinction between an office visit and a hospital outpatient encounter or emergency room claim can be boiled down to a small two-digit POS code. Incorrect code can reduce payment rates or age claims, or worse, raise compliance concerns with the CMS.
In this comprehensive guide, we’ll clarify just what POS code 11 is, how it impacts reimbursement, the distinction between office and hospital billing, and why accurate coding is crucial for compliance come 2025. As a billing professional, whether you provide or pay, we provide you with all the necessary information to apply POS 11 in medical billing correctly.
What is POS 11 in Medical Billing? (The Definitive Answer)
So, what does POS 11′ mean? CMS defines Office as the POS 11 code. It informs the insurance payer of where the patient was seen (in a physician’s office or clinic) and that the service was provided in an outpatient setting.
This is a non-facility code, meaning it was the physician’s own practice (not a hospital at all) where the setting and supply occurred. That one difference results in an entirely different reimbursement amount, as the burden of these overhead costs shifts from a facility to the provider.
For instance, a child’s immunisation at a paediatrician’s independent clinic would be POS 11, whereas the same immunisation provided within a hospital outpatient department would be POS 22. Both services are identical from a medical standpoint, but it’s the code that drives the payment.
Place of Service Codes List: Facility vs. Non-Facility Distinction
This CMS-generated list was used to classify all codes as either facility or non-facility site of service codes.
- POS Codes for Non-facility Sites of Service – Place of Service Code Set Office-Based (22) The location where the patient is treated in a place maintained by recovery, treatment, or other services targeted at those with mental or substance abuse issues. Examples: POS 11 (Office), POS 12 (Home), or POS 15 (Mobile Unit).
- Facility POS codes – Services in hospital-owned or institutional settings. Examples: POS 21 (Inpatient Hospital), POS 22 (Outpatient Hospital), POS 23 (Emergency Room).
What sets POS 11 apart from other non-facility POS codes is that it specifically refers to office visits, as opposed to home visits (POS code 12), nursing facilities (POS code 31), and residential care facilities (POS code 32). Many payers, including Medicare, place restrictions on the use of telehealth services. Providers report HCPCS code POS 11 for the majority of in-person routine outpatient services provided to a patient. POS 11 reflects such care in private practice.
POS 11 Billing Guidelines: When Should I Use POS 11 in Medical Billing Claims?
The POS 11 billing rules are plain and simple, yet you need to be attentive when following them:
Use POS 11 when:
- Presentation in a physician’s office or clinic.
- It is an outpatient (you go home the same day) service.
- Office resources and staff are available to support you.
- Do not use POS 11 when:
- The service was performed in a hospital or ER (use POS 21, 2,2, or 23).
- The service was rendered telehealth (use POS 02 or POS 10).
- The office is owned and billed under a facility using hospital place-of-service codes.
- Proper use means no claim denials and accurate reimbursement.
Is POS 11 Inpatient or Outpatient? (Clarity on code type)
To clarify, POS 11 is always considered an outpatient.
There are no “inpatient admissions” out of a doctor’s office. When a patient is admitted to the hospital, the correct codes are POS 21 (Inpatient Hospital) or POS 31 (Skilled Nursing Facility). 99% will receive denials or audits if one attempts to call inpatient as POS 11.
POS 11 vs. POS 22: The Crucial Reimbursement Difference
What are the POS 11 & POS 22 codes in billing? They are discussing outpatient care in two drastically different instances.
- POS 11 – Office: An independent clinic or private practice in which the physician is responsible for overhead expenses.
- POS 22 – Hospital Outpatient Department – A hospital facility or clinic owned by a hospital that is primarily organised to provide surgical services.
This difference directly impacts reimbursement.
Payment Differential Analysis: Which POS code has higher reimbursement: POS 11 or POS 22?
The difference in reimbursement is obvious, with POS 11 often reimbursing more than POS 22.
Why? In POS 11, the doctor is paying rent, staff, utilities, and supplies. To offset those costs, Medicare and private insurers pay for office visits at the full non-facility rate.
In POS 22, however, the hospital receives a share of the revenue for providing infrastructure, thereby reducing the percentage that goes to the physician. This is the reason 20-30% of reimbursements are being lost when providers bill POS 22 incorrectly instead of POS 11.
How does POS 11 impact medical billing reimbursement? (The financial outcome)
Coded properly, the relevant provision of POS 11 influences reimbursement by:
- High non-facility payment rates are being achieved.
- Decrease in unnecessary delays as the majority of routine office claims are anticipated under POS 11.
- Mitigating improvident claim denials as a result of location mismatch.
Billing reviews: An audit of charging suggests that false POS coding is initially used for underpayment. Another internal medicine company lost 25% of its revenue before discovering it was erroneously sending claims with POS 22 rather than POS 11.PRACTICES: PREVENTATIVE MEASURES AGAINST ADT S TRANSAXIAL reports (2011) that the implementation of preventative measures when submitting any claim can drastically reduce denials related to such errors.
Mastering Key Comparison Codes
Providers should identify POS 11 when used as a unique place of service code distinct from other frequently used place of service codes for billing purposes.
Difference between POS 11, POS 21, and POS 23
Providers should identify POS 11 when used as a unique place of service code distinct from other frequently used place of service codes for billing purposes.
- POS 11, POS 21, and POS 23 in comparison
- POS 11 (Office) – Office visit: outpatient care in a physician’s office.
- POS 21 (Inpatient Hospital) – patient is admitted and remains at least one night.
- POS 23 (Emergency Room – Hospital) – Emergency room services for urgent or life-threatening conditions.
Those codes apply to entirely different healthcare settings, but providers frequently mix them up when noting down patient visits. POS 21 hospital inpatient billing and POS 23 ER billing codes should never be substituted for or replaced with POS 11.
POS 22 vs. POS 21, Outpatient Billing Code: Clarifying Hospital Outpatient vs. Inpatient
- POS 22 (Hospital – Outpatient): Services provided on hospital premises, with the patient returning home on the same day.
- POS 21 (Inpatient Hospital): The patient is admitted and stays for at least one night.
Looking beyond both, POS 11 is targeted for independent offices that are not associated with hospital-based systems. This makes the office setting an anomaly when it comes to calculating reimbursement.
POS 11 in the Modern Era: Telehealth, Denials, and Regulatory Authority
Healthcare billing has undergone a significant transformation with the expansion of telehealth and new CMS regulations. Many practices wonder where POS 11 fits in the current system.
- POS 11 and Telehealth: When billing for telehealth, do you bill under POS 11, POS 02, or POS 10?
- Currently, telehealth is not under POS 11.
- POS 02 – Telehealth not in the patient’s home (e.g., a clinic or other site).
- POS 10 – Originating site by means of telepresenting the patient (patient is at home).
- POS 11 — For office visits only, not for virtual care.
During the COVID-19 pandemic, CMS temporarily permitted the use of POS 11 for telehealth services. As of 2025, telehealth services should be billed using POS 02 or POS 10.
CMS Authority and Documentation: How to Ensure Correct POS 11 Usage on Claims According to CMS Guidelines?
- CMS officially defines POS codes. To stay compliant, providers must:
- Clearly record the site of service in patient records.
- Ensure the EHR automatically assigns POS 11 for office visits.
- Educate your staff on CMS changes often.
- Perform internal “audits” to trace miscoding before it gets out of hand.
The Claim Lifecycle: What are revenue codes for medical billing, and what is their connection to POS 11?
These are codes used to indicate the kind of service or department (e.g., 0510 is for clinic services). POS codes and revenue codes are used to indicate both the site of service and the type of service being provided.
For example:
- What POS 11 + Revenue Code 0510 → Physician office clinic visit.
- POS 22 + Revenue Code 0510 → Hospital outpatient clinic visit.
Insurers will often deny the claim if POS 11 and revenue codes don’t match. Proper matching is crucial to RCM and the filing of clean claims.
Mitigation Strategy: Avoiding Common POS 11 Mistakes
Mistakes on POS 11 charges are so prevalent, yet they’re also avoidable.
What are the common mistakes when using POS 11, and how can they be avoided?
- Billing Inpatient Hospital under POS 11 … all Other POS.
- Billing POS 11 for telehealth visits instead of POS 02/10.
- Filing Claims Using Old Tariff Software.
- Staff accidentally entered POS 22 for office visits.
- Lack of documentation to demonstrate where the service was performed in an office.
Prevent these issues with staff training, software updates, and regular monthly audits.
What happens if the wrong POS code is used on a claim? (Addressing the consequence)
The use of incorrect code results in:
- Lower reimbursement (underpayments).
- Claim denials and resubmissions.
- Overpayment requests may be made if an audit identifies faulty coding.
- Being at the mercy of Medicare and commercial payers.
One orthopaedic group had to refund $80,000 after billing for outpatient therapy (POS 21) was improperly submitted. These cases demonstrate the significance of coding correctness.
Frequently Asked Questions (FAQs) for POS 11 Usage
Understanding Documentation Requirements for POS 11
To be compliant with CMS, providers need to document the:
- Ig series date of service and place of service (doctor’s office).
- Provider credentials.
- CPT/HCPCS codes.
- Patient’s clinical details.
This allows claims to be defended in payer reviews.
Occurrence Code 11 vs. POS 11: Why the Distinction Matters
- Occurrence Code 11 – Date of symptom onset for hospital billing (UB-04).
- POS 11- Place of service: doctor’s office.
Combining them leads to coding conflicts and rejections.
Final Thoughts:
In health care billing, precision’s the name of the game. The definition of Place of Service 11 is not limited to an Office — it also applies to reimbursement rates, CMS guideline compliance, practice financial health, and more.
- If POS 11 is used appropriately, providers can:
- Secure higher non-facility reimbursement.
- Reduce claim denials.
- Strengthen compliance under CMS authority.
Many providers to maintain practice volume and stay ahead of changing regulations choose experienced RCM specialists like CareSolutions, with significant expertise in coding accuracy, compliance, and denial prevention.”
It’s not just about codes; it’s about delivering sustainable financial results in today’s healthcare world.
FAQ’s:
What is the 11th place of service?
Place of Service 11 indicates the care was provided in a doctor’s office or private practice. It designates the visit as outpatient and places the obligation on staff, rent, and resources. Accurate coding leads to higher non-facility payment rates and fewer denials, he adds.
What is location 11?
Billing location 11 is in a doctor’s office, not a hospital or institution. It is billed for services that are performed at an outpatient clinic that the provider owns. This enables payers to process claims accurately in accordance with CMS rules.
Where are POS 11 and POS 22 in the medical billing process?
POS 11 describes services in a doctor’s office with non-facility charges, and POS 22 is for hospital outpatient departments. The major distinction is payment: office-based visits are typically more lucrative because the doctor, not the hospital, covers overhead.
What is meant by place of use?
Place of Service (POS) codes are two-digit identifiers on a claim that indicate where the service was performed. CMS controls them; they also differentiate office visits, hospital care, telehealth, and other settings. When that plan is accurate with POS coding, the bill comes out right, and so does compliance.
What is POS 10?
Telehealth visits rendered while the patient is at home – POS 10. It distinguishes home-based virtual care from telehealth at a clinic or facility. POS 10 ensures that providers are properly reimbursed for telemedicine services in accordance with CMS guidelines.
What is CMS code 11?
CMS officially defines CMS code 11 as a physician’s “Office,” where the majority of health professionals offer outpatient services. It’s not just for physicians, but for all licensed providers. Office-based services billed with POS 11 are paid non-facility.
What data is entered on a CMS/HCFA 1500 claim form in block 11?
Under block 11 in the CMS claim form, it is necessary to include a nine-digit payer ID for the primary insurance company. If not, the complete payor name and claims processing address will be included. This is to ensure the claim travels correctly for reimbursement.
