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Everything a Healthcare Provider Should Know About POS 11 in Medical Billing | Complete Guide

In medical billing, every error counts. Even if it is a misplaced POS code or an irrelevant modifier, your claim may get denied for the slightest mistakes. Mistakenly placed POS 11 in medical billing is one of the most common reasons for the recent denials by most payers. 

Place of service code 11 is used by physicians and healthcare providers who provide services in their private offices. Clinics and offices that are part of a hospital or are documented as a dedicated department of a specific hospital are not eligible for POS 11 code.

In this blog, we will highlight the differences between different POS codes and will walk you through when and where to use which specific POS code. Let’s dive straight into the topic.

What are POS Codes?

POS is an abbreviation for “point of service” in medical billing. POS codes are two-digit numbers that help the insurers understand the place where the service was provided. CMS has assigned specific POS codes to different places such as hospitals, private clinics, schools, home, office, etc. To simplify the process, the POS codes are divided into two main categories: Facility and Non-facility POS codes.

Facility vs. Non-Facility POS Codes

Facility POS codes as the name shows are used for services provided in skilled healthcare facilities such as hospitals, nursing homes, emergency rooms, urgent care centers, etc. The insurance companies need to understand the degree or the type of the facility where the services were provided, in order to send the reimbursements. 

Non-facility POS codes, on the other hand, are used for services that are provided outside of a regular heatlhare setting. These include places such as schools, homes, private clinics, and offices. Family doctors, physical therapists, or dentists providing services at the patient’s home or at their own private clinics need to use non-facility POS codes.

POS Code Place of Service Description Facility Type
11
Office
Non-Facility
19
Off-Campus Outpatient Hospital
Facility
22
On-Campus Outpatient Hospital
Facility
21
Inpatient Hospital
Facility
23
Emergency Room – Hospital
Facility
31
Skilled Nursing Facility
Facility
32
Nursing Facility
Facility
49
Independent Clinic
Non-Facility
50
Federally Qualified Health Center (FQHC)
Facility
72
Rural Health Clinic
Facility
65
End-Stage Renal Disease Treatment Facility
Facility
81
Independent Laboratory
Non-Facility
53
Community Mental Health Center
Facility
15
Mobile Unit
Facility
02
Telehealth Provided Other than in Patient’s Home
Varies (Typically Non-Facility)
10
Telehealth Provided in Patient’s Home
Non-Facility

What is Place of Service 11 in Medical Billing?

The official definition of POS 11 as per the Centers for Medicare & Medicaid Services (CMS) guidelines is:

“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 the health professional routinely provides health examinations, diagnosis, and treatment of illness or injury.”

In simple words, POS 11 code is used by healthcare providers who see a patient in-person at a private practice, clinic, or group practice that is not affiliated, associated, or part of a hospital setting.

When Is POS 11 Used?

POS 11 is used whenever a patient physically visits the provider’s office for an evaluation, procedure, consultation, or follow-up service. It’s the most common POS code for outpatient, non-facility care. Below are a few common examples of services billed under POS 11.

However, any of these services that have to be billed under the POS 11 code must be provided at the doctor’s private clinic or office. If not, be ready to expect a denial or delay in your payments, or even something worse like an audit.

Documentation Requirements for POS 11 Billing

Proper documentation is the backbone of medical billing. Since the reimbursement rates for non-facility codes such as POS 11 is higher than facility codes, payers or insurance companies closely scrutinize such claims to make sure everything is legit before sending out the reimbursements. 

To justify billing with POS 11, the following documentation must be included in the patient’s medical record:

Incorrect or incomplete documentation for POS 11 can result in delayed or denied claims. In some situations, the payer may ask for an audit or may request records for clarifications. Retroactive audits may result in recoupment of payments if the documentation does not support the used POS code. 

In scenarios where the provider practices medicine across different locations, the billing team must collaborate with the provider to ensure the right use of the POS codes.

Common Billing Errors Related To POS 11

With medical billing comes the billing errors. Even experienced billing teams can make errors, especially in the case of POS 11 code, due to confusions and miscommunications. Below are the most common issues or reasons for billing mistakes in using POS 11 code.

In scenarios where the provider practices medicine across different locations, the billing team must collaborate with the provider to ensure the right use of the POS codes.

Using POS 11 When Service Was Done in a Facility

This happens mostly when the doctor provides the service at a hospital-owned outpatient clinic but the billing team bills it using POS 11 instead of POS 22. Since the reimbursement rates for POS 11 is higher than non–facility codes, such mistakes might result in compliance issues. Billing teams must be provided clear information about the location of the service to ensure a smooth billing cycle.

In scenarios where the provider practices medicine across different locations, the billing team must collaborate with the provider to ensure the right use of the POS codes.

Incorrect Modifier Usage

Modifiers in medical billing help clarify the context of a service. Missing or misused modifiers (like -25 for E/M with procedures) may lead to claim denials or downcoding. Billing teams should always review payer-specific modifier policies.

Telehealth Confusion

Billing a virtual visit as POS 11 without proper telehealth indicators (like POS 10/02 or modifiers 95/GT) is a common and costly mistake. As it misrepresents the setting of the service, healthcare providers may even face fraudulent charges for such mistakes. Claim denials and recoupments are the least severe outcomes for this mistake.

POS Code   Setting Used For
02
Telehealth Provided Outside Patient’s Home
Office, clinic, or other remote sites
10
Telehealth Provided in Patient’s Home
Home-based virtual care
11
Office (In-person Only)
Face-to-face visits performed physically in a doctor’s office

Best Practices for Correct POS 11 Use

Using POS 11 correctly isn’t just about applying the right code. Your billing team might be applying the right code but as per the latest payer-guidelines they may not be accurate. To avoid such a situation, here are some best practices that every healthcare provider should ensure for the correct POS 11 use.

Staff Training for Front Desk and Billing Teams

Your front desk and billing staff are the first line of defense against coding errors. Make sure they understand the basic billing nuances such as the difference between facility and non-facility setting, when and how to apply POS 11, and how to communicate with providers about the service location. In-house audits and regular training sessions of the team can greatly improve your billing accuracy.

Using EHR Prompts and Location-Based Reminders

Modern EHR systems allow you to set rules or alerts based on encounter types or provider locations. Healthcare providers or the billing team can use these tools to automatically populate the POS field based on appointment location. Moreover, these tools can flag mismatches between encounter type and POS code.

Double-Check the Location Field on Every Claim

Before any claim is submitted, the POS field should be reviewed manually by the billing team. It is crucial for practices where providers rotate between office locations, hospitals, patient homes, and telehealth platforms. Minor errors, such as defaulting every claim to POS 11, can cause compliance issues and reimbursements delays or revenue loss.

Maintain Payer-Specific POS Cheat Sheets

Every payer has a unique process of scrutinizing claims for reimbursements. Successful billing teams maintain a simple internal cheat sheet of their payer policies that helps them stay compliant with coding nuances, modifier requirements, and reimbursements policies. Maintaining such a simple internal cheat sheet can help you increase your billing accuracy and get timely reimbursements. 

P.S. Update your cheat sheets at least quarterly or whenever major payer updates occur.

Hiring a Professional Billing Team is a Great Option

Cut the hassle of dealing with billing and coding guidelines and policies by hiring a professional billing team. Billing companies like Mediclaim Pro Billing can help you manage all your billing processes without any effort. They have certified coders, AR experts, and billing professionals, who know the ins and outs of today’s revenue cycle management for healthcare providers. 

Besides, hiring a virtual billing team helps healthcare providers cut overhead costs. These are highly recommended for private practice owners and small practices as they are highly cost effective and reliable. However, make sure you get the right team or you might be putting your practice to risk.

Frequently Asked Questions

Is POS 11 the same as an outpatient clinic?

Not exactly. POS 11 code is specifically used when the service is provided at a physician’s office or private practice where the provider bears the overhead costs. You may use POS 11 for an outpatient clinic as long as it is not a part of a hospital or any healthcare facility.

What happens if I accidentally use POS 11 for a hospital-based service?

Accidentally using POS 11 for a hospital-based service may result in claim denials or recoupments (in case of retroaudits). As the reimbursement for this code is higher, it will be considered as overbilling and may raise serious legal problems for your practice. The best way to get out is to immediately submit a corrected claim as some payers may allow adjustments if done proactively.

Can I use POS 11 if I rent space inside a hospital building?

The use of POS 11 in such a scenario depends on whether the space is independently opearted by you or if it is considered part of the hospital’s outpatient system. If you pay rent directly and control the scheduling, staff, and other expenses, than you should use POS 11. However, if your services are billed through hospital billing, then you should use hospital POS codes.

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