Let’s say you’re a provider seeing patients in your private practice. You wrap up a few appointments, submit claims like clockwork—and then boom! A claim comes back denied or underpaid.
The culprit?
Often, it’s the Place of Service (POS) code.
In this post, we’re breaking down POS 11—one of the most common but misunderstood POS codes in medical billing.
We’ll look at what it means, how it impacts your revenue, and how to avoid the costly errors that can sneak in.
Let’s dive right into it.
POS 11 in Medical Billing
POS 11 stands for “Office” in medical billing. It refers to a non-hospital, freestanding office location where the healthcare provider sees patients face-to-face. It’s often used in:
- Private practices
- Group medical clinics
- Physician-owned medical offices
In simple terms, if you’re seeing a patient in your clinic, POS 11 is your go-to code.
This POS code goes on your CMS-1500 form or electronic claim and tells the payer, “Hey, this service happened in a regular office setting—not a hospital or facility.”
Services Billed Under POS 11
You can use POS 11 for a wide range of services, especially Evaluation and Management (E/M) codes and standard in-office procedures.
Some popular CPT codes billed with POS 11 include:
- 99202–99215 (Office visit E/M codes)
- 36415 (Routine venipuncture)
- 93000 (Electrocardiogram)
- 20610 (Joint injection)
- 81002 (Urinalysis, non-automated)
These are services typically rendered in a traditional office where no facility fee is involved.
Quick Comparison Table: POS 11 vs Other Codes
| POS Code | Description | Typical Setting | Facility Fee? | Common CPTs Used |
| 11 | Office | Private clinic or group office | No | 99202-99215, 93000, 81002 |
| 22 | Outpatient Hospital | Hospital-based outpatient dept | Yes | 99201-99215, facility mod |
| 21 | Inpatient Hospital | Hospital room visits | Yes | Inpatient E/M, 99221-99233 |
| 02 | Telehealth | Virtual consult (interactive) | No | 99441-99443, 99212-99215 |
Mislabeling POS can result in underpayment or claim denial, especially when insurers calculate reimbursement based on facility vs non-facility rates.
How does POS 11 affect reimbursements?
POS 11 directly affects your reimbursement rate, and here’s the kicker: Medicare and commercial payers pay differently depending on POS.
Let’s break down three scenarios.
Scenario 1: Office Visit vs Hospital Outpatient Visit
You perform a 99214 E/M service.
- In your private office (POS 11), Medicare pays you the full non-facility rate, say $120.
- In a hospital outpatient clinic (POS 22), you get the facility rate, closer to $90.
The hospital bills a facility fee separately, and you lose that $30 difference.
Billing POS 22 instead of POS 11 when you’re in your own office? That’s money left on the table.
Scenario 2: Modifier Mismatch
You bill CPT 96372 (therapeutic injection) with POS 11, but your claim includes modifier -TC (technical component). Now Medicare thinks you’re billing a facility service—not an office visit.
Result?
Claim denial.
Scenario 3: Telehealth Visit Labeled as POS 11
During the COVID-19 PHE, some payers allowed POS 11 for telehealth to ensure non-facility reimbursement. But now, most want POS 02 or 10.
Billing POS 11 for a virtual visit today?
Risk of denial or overpayment clawback.
Common Mistakes with POS 11
POS 11 looks simple on the surface. But small mistakes with it can seriously mess up your claims, delay payments, or worse—trigger audits.
Here’s a closer look at the most common errors providers and billing teams make with POS 11, and why they matter:
Using POS 11 in a Facility Setting
You’re seeing a patient in a hospital-owned outpatient clinic, but your claim says POS 11 (office).
That setting isn’t an independent office—it’s a hospital facility, and you should be using POS 22. Billing POS 11 misrepresents the site of service, which could cause:
- Claim denials
- Payment recoupments
- Compliance issues
Even if it feels like a regular office, if a hospital owns it, it’s not POS 11.
Not Matching POS with CPT Code Requirements
You bill a CPT code like a Medicare Annual Wellness Visit (G0438) with POS 11—but Medicare has strict POS rules for preventive services.
Some services are only covered or reimbursed when done in specific settings. If your POS doesn’t match what’s allowed for the CPT code, you’ll get:
- Partial payment
- Claim rejection
- Lost time fixing the error
Some CPTs aren’t billable under POS 11 at all.
Incorrect POS During Telehealth Billing
You’re billing a telehealth visit (maybe via Zoom or EHR video) but still using POS 11 out of habit.
After the COVID-19 public health emergency ended, most payers updated their telehealth POS requirements. They now want:
- POS 02 – Telehealth outside the patient’s home
- POS 10 – Telehealth in the patient’s home
Billing POS 11 for a virtual visit today can result in:
- Immediate claim denial
- Overpayment recovery requests
Coding with Facility Modifiers (-TC / -26)
You’re billing technical (-TC) or professional (-26) modifiers with POS 11.
POS 11 represents a non-facility setting. That means you, the provider, are responsible for both the technical and professional components.
If you split the components and bill it like it’s a facility:
- Medicare or commercial payers will flag the claim
- You may get underpaid or denied
Only use -TC or -26 in facility settings (like POS 22 or 21), not POS 11.
Wrong POS in EHR Claim Exports
You move between clinics or settings, but your EHR keeps defaulting to POS 11 for every claim.
This leads to:
- Incorrect billing location
- Compliance risks if audited
- Denials if your claim doesn’t match patient encounter details
For example, you saw a patient in a hospital suite, but your system tagged POS 11. That claim will likely get rejected.
How to Avoid POS 11 Mistakes?
Avoiding POS 11 errors doesn’t take magic. It takes good systems, regular training, and clean billing habits.
Here’s how you can keep things tight:
Train Your Billing Staff Regularly
Your billers are the last line of defense. If they don’t understand the difference between POS 11 and POS 22, errors are bound to happen.
- Host quarterly training.
- Review POS code definitions, payer rules, and denial trends.
- Add POS scenarios to your staff onboarding process.
Use EHR Smart Logic or Location Mapping
Modern EHRs and billing platforms like Kareo, Athenahealth, or DrChrono allow you to link a location to a POS code.
Configure each location in your EHR so that POS 11 is only applied to your actual office, not other sites like surgery centers or hospitals.
Double-Check CPT and POS Code Pairing
Not all CPT codes can be billed under POS 11. Some need to be in a facility or telehealth settings.
Use a billing cheat sheet or payer coding guide to confirm that your CPT codes are allowed under POS 11 before submitting claims.
Stay Updated with Payer Rules (Especially Telehealth)
Payers change POS policies frequently. What worked last year might get denied this year.
Subscribe to payer newsletters, join billing forums, or assign a team member to track payer guideline changes every quarter.
Conduct Monthly POS Claim Audits
Audits catch mistakes early—before payers do.
Pull a monthly POS report from your EHR or billing system. Look for:
- POS 11 is used for inpatient or telehealth visits
- Modifiers misaligned with POS
- High volume of POS 11 denials
Correct them before they become bigger issues.
Conclusion
POS 11 might seem like a small part of your claim, but it can make a big difference in your revenue. Understanding when and how to use this code—especially in the post-COVID billing environment—is key to maximizing your reimbursements and avoiding denials.
Whether you’re a solo practitioner or part of a group practice, getting POS 11 billing right will keep your revenue cycle smooth, clean, and compliant.
Frequently Asked Questions (FAQs)
What does POS 11 mean in medical billing?
POS 11 refers to an office setting, typically a non-hospital-based clinic, where providers render face-to-face care.
Can I use POS 11 for telehealth services?
Not anymore in most cases. After COVID-19 rules expired, POS 02 or 10 is now required for most virtual care billing.
How does POS 11 affect reimbursement?
Billing POS 11 usually leads to higher reimbursement than facility POS codes, as there’s no facility fee split involved.
What’s the difference between POS 11 and POS 22?
- POS 11: Office setting, no facility fee
- POS 22: Hospital outpatient clinic, shared billing with facility
How can I audit my POS 11 usage?
Use your EHR system’s reporting tools or billing software to pull claims by POS code. Look for mismatches in CPT and POS, and review rejected claims for POS-related denial reasons.
