According to the Centers for Medicare & Medicaid Services (CMS), billing staff often do not know where their physicians performed certain services, such as diagnostic test interpretations. Either that or they simply do not understand place of service (POS) codes enough to make informed decisions.

“The use of office or POS code 11 in certain situations has been problematic,” CMS says in a recent transmittal.

The POS code on a claim designates the actual place where a service was provided. It also determines whether the provider is paid at the facility or non-facility rate under the physician fee schedule (PFS).

To clarify, CMS says, physicians who perform services for an ambulatory surgical center (ASC) should use POS code 24, not POS code 11. Only if the physician has an office at the ASC and the service is performed in the office would POS code 11 be appropriate. “However, no concurrent or overlapping hours can exist between the ASC and the physician’s office,” CMS stipulates.

Physicians who perform services in a hospital outpatient department should use POS code 22. Unless, that is, the physician maintains separate office space in the hospital or on hospital property that is not considered a provider-based department of the hospital. In that case, and providing the service was performed in the physician’s office and not in the hospital, POS code 11 would be appropriate.

This assumes, of course, the physician is not working under arrangement for the hospital; in which case both the technical and professional components fall under global services. In that case, the hospital is the only entity that can bill for the diagnostic test, which includes interpretation.

What if your physician interprets an image at home or in a hotel room? Report POS code 99 or “other” — unless, of course, the space meets the definition of an office. Even then, if both the physician and the patient are present in the hotel room at the time of the interpretation, POS code 16 (temporary lodging) is more appropriate.

Remember: The POS code should coincide with the ZIP code identified on the claim form; and the ZIP code should coincide with the office practice location given in the physician’s enrollment information. When in doubt, contact your Medicare contractor for guidance.

Read CMS Transmittal 1823, Change Request 6375, issued Oct. 2, for further details.

4 Responses to “POS Codes: Do You Know Where Your Doctor Is?”

1. Marie Curle Says:
   October 26th, 2009 at 7:29 am

   I recently called Medicare regarding tests that one of my physicians read at home. According to Trailblazer we would bill the POS that the physician was enrolled with at Medicare. If the physician is an office based provider then we could bill out POS 11. If the physician was a hospital or facility based provider then the POS would be 22 or 21. In the above article you state to use POS 99 for an interpretation who did you receive this information from?

2. renee Says:
   October 29th, 2009 at 3:48 am

   The transmittal listed in the article.

3. Michelle Says:
   November 5th, 2009 at 10:01 am

   My issue is a provider see a patient on the floor in L&D that is 20+ weeks pregnant for an acute issue such as abdominal pain, bleeding, etc. The patient is listed as Observation status on the hospital roster. I feel the place of service is 22 for outpatient. However, some providers outside of our practice are billing ER e&m codes that do not coincide with the place of service.

   Is there an instance where L&D can be considered ER? My thoughts are NO – What do you know?

4. Zita Bigler Says:
   May 20th, 2011 at 8:34 am

   Hello and thank you for taking the time to read my comment. I am trying to get a listing of POS codes for all US hospitals. Can you tell me how I can go about getting this list?

   Thanks so much.
   Zita

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