POS 11 is the place of service code for a physician office and pays the higher non-facility rate. POS 22 is on-campus hospital outpatient and pays the lower facility rate, because the hospital bills the overhead separately. For 2026 the gap widened sharply: a level 4 established visit pays about $135.61 under POS 11 and about $84.50 under POS 22, a difference of more than $51 on a single ordinary claim.
Place of service is two digits on a claim line and it is one of the least examined fields in medical billing. It also became, in January 2026, one of the most financially consequential. If your organization bills across more than one setting, the CY2026 fee schedule quietly changed the arithmetic underneath every claim you send.
What POS 11 and POS 22 actually mean
Place of service tells the payer where the service happened, which determines which of two payment rates applies to the professional claim.
| Code | Setting | Rate applied | Who carries the overhead |
|---|---|---|---|
| 11 | Office | Non-facility | The practice, so the practice is paid for it |
| 19 | Off-campus hospital outpatient | Facility | The hospital, billed separately |
| 22 | On-campus hospital outpatient | Facility | The hospital, billed separately |
| 10 | Telehealth, patient at home | Non-facility | The practice |
| 02 | Telehealth, patient not at home | Facility | The originating site |
The logic is straightforward once stated. The non-facility rate bundles practice expense, meaning staff, rent, equipment, and supplies, into the physician payment. The facility rate strips most of that out because the hospital claims it on its own institutional claim. Billing POS 11 for a service delivered in a hospital outpatient department is not a technicality. It is asking Medicare to pay overhead twice.
The POS 10 and POS 02 pair deserves its own attention, because telehealth is where the mistake is most common and least noticed. A patient at home is POS 10 and attracts the non-facility rate. A patient in a clinic or facility during a telehealth encounter is POS 02 and attracts the lower facility rate. Practices that default every telehealth claim to POS 02 out of habit are underbilling every single one.
Why 2026 widened the gap
CMS finalized a significant change to indirect practice expense allocation in the CY2026 Physician Fee Schedule. Reasoning that physician practice has shifted substantially toward hospital employment and integration, and that facilities now bear those indirect costs, CMS reduced the portion of practice expense RVUs allocated to services performed in facility settings to half the amount allocated in non-facility settings.
The result was a split rather than a uniform update. Office-based payment for common visit codes rose. The identical code performed in a hospital outpatient department fell.
| Code | 2026 POS 11 (office) | 2026 POS 22 (facility) | Gap |
|---|---|---|---|
| 99213 | $95.19 | $57.45 | $37.74 |
| 99214 | $135.61 | $84.50 | $51.11 |
| 99215 | $192.39 | $125.59 | $66.80 |
For context on direction of travel: 99214 rose about 8.3% in the office from $125.18 in 2025, and fell close to 10% in a facility from $93.80. The work RVU of 1.92 did not change in either setting. The entire movement is practice expense. Figures are national amounts before geographic adjustment, so confirm your own locality through the CMS Physician Fee Schedule lookup.
Two consequences follow that most practices have not yet worked through. First, if your compensation model runs on work RVUs, your production looks identical while the organization’s collections have moved, which creates a real conversation about how facility-based physicians are paid. Second, provider-based conversions and off-campus expansions now carry a professional-fee cost that did not exist at the same scale a year ago.
How POS errors actually happen
Almost never through ignorance of the rule. The failures are operational.
- The default in the practice management system. One POS value is set as the template default and every claim inherits it. This is the single largest cause and the easiest to fix.
- Physicians who work across settings. A surgeon with clinic days and hospital days needs POS to follow the schedule, not the provider record.
- Provider-based clinics. A practice acquired by a health system often keeps billing POS 11 for months after the designation changed, which is an overpayment accumulating quietly toward a refund demand.
- Telehealth defaults. POS 02 applied universally, when most encounters are patients at home and belong in POS 10.
- Off-campus versus on-campus confusion. POS 19 and POS 22 both pay facility rates, so the financial stakes are lower, but they are not interchangeable and payers do audit the distinction.
The controls that catch it
POS is a field an edit can validate, which makes this one of the cheaper problems in revenue cycle to solve properly.
- Scrub POS against the rendering location and the provider’s schedule before submission, not after. This is a standard edit inside claim scrubbing services.
- Reconcile paid amounts against expected non-facility and facility rates on every remittance. A claim paid at the facility rate when POS 11 was submitted is either a POS error or a payer error, and both are worth knowing about. This sits inside payment posting and reconciliation.
- Audit by provider and by month rather than in aggregate. A single physician with a wrong default can produce a five-figure annual variance invisible in a practice-level report.
- Re-verify POS designation after any acquisition, relocation, or provider-based conversion.
Where the error ran the other way and claims were systematically paid at the facility rate that should have been non-facility, the money is recoverable through underpayment recovery. Where POS drove denials, they belong in denial management. For multi-site groups this is a routine part of clinic and physician group RCM, and for health systems it belongs in hospital revenue cycle management.
If you want the variance quantified before you change anything, a free instant revenue audit will size it by provider and setting. Place of service is one of several 2026 changes that arrive as reduced payment rather than as a denial, a pattern covered across the biggest revenue cycle management challenges in 2026.
Frequently asked questions
What is POS 11 in medical billing?
Place of service code 11 designates a physician office and triggers the higher non-facility payment rate, because the practice bears the overhead for staff, space, and supplies and is paid for it within the professional fee.
What is the difference between POS 11 and POS 22?
POS 11 is an office and pays the non-facility rate. POS 22 is on-campus hospital outpatient and pays the lower facility rate, because the hospital bills the overhead on a separate institutional claim. In 2026 the difference on 99214 is more than $51.
Which POS code should I use for telehealth?
POS 10 when the patient is at home, which pays the non-facility rate. POS 02 when the patient is somewhere other than home, which pays the facility rate. Defaulting all telehealth to POS 02 underpays most claims.
What happens if I bill the wrong place of service?
Billing POS 11 for a facility service creates an overpayment and refund exposure, because Medicare pays practice expense the hospital also claims. Billing a facility POS for an office service simply underpays you, permanently, unless you catch and correct it.
Did place of service payment change in 2026?
Yes. CMS reduced the indirect practice expense allocated to facility settings to half the non-facility allocation, which raised office rates and cut facility rates for the same codes. The work RVUs did not change.
Does POS 19 pay the same as POS 22?
Both apply the facility rate, so the professional payment is the same. They are still distinct codes for off-campus and on-campus outpatient locations, and using them interchangeably is a compliance risk even where the payment does not differ.