What Is Place of Service 11?
“Place of Service (POS) 11” is a billing code used in U.S. healthcare claims to indicate that a medical service was provided in a physician’s office (or similar private clinic).
More precisely, CMS defines POS 11 as:
“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 on an ambulatory basis.
In simpler terms: when you see a patient in your own office (not in a hospital setting), you would use POS 11 for the claim.
Why POS Codes Matter
Place of Service codes give payers (insurance, Medicare, etc.) context for where a service was delivered. That context helps determine:
- Which reimbursement “bucket” applies (office vs hospital)
- Whether facility overhead is being covered
- Whether the claim is consistent with documentation
Using the wrong POS code can delay payment, trigger denials, or even lead to audits.
POS 11 is among the most common, especially for outpatient care in private practices.
When to Use POS 11: Key Criteria
To use POS 11 correctly, the service must meet certain conditions. Here are the main criteria:
- It is an office-based setting
The provider’s own office or clinic—not a hospital outpatient department or facility. - Provider control & ownership
The physician or group operates or controls the practice (staffing, rent, utilities) rather than it being a hospital department. - Routine, outpatient services
The services are evaluation/management, diagnostics, minor procedures, etc., done without inpatient stay. - No separate facility claim
Since POS 11 assumes that the provider bears all the overhead, there is typically no separate facility fee billed.
If any of these are violated (for example, the clinic is hospital-owned, or service is in a hospital outpatient wing), another POS code (often POS 22) may be correct.
POS 11 vs POS 22 (and Others): What’s the Difference?
It’s common to confuse POS 11 with POS 22 (hospital outpatient). Understanding their differences is crucial.
| Feature | POS 11 (Office) | POS 22 (On-Campus Outpatient Hospital) |
|---|---|---|
| Setting | Independent office or clinic | Hospital outpatient department or hospital-owned clinic |
| Overhead burden | Physician covers office overhead | Hospital bears facility costs |
| Reimbursement | “Non-facility” rate (higher for provider) | “Facility” rate (lower for provider’s portion) |
| Facility fee | No separate facility billing | Hospital may bill facility fee separately |
| Common misuse | Billing in hospital-owned clinics wrongly | — |
Using POS 11 when POS 22 is correct can lead to underpayments, denials, or payback demands.
How POS 11 Affects Reimbursement & Claims
- Higher professional payment
Because POS 11 assumes the provider bears overhead, insurers often pay a higher “non-facility” rate than in hospital settings. - Simpler claims structure
The claim usually includes only the professional fee (no separate facility billing). - Risk of denials if misused
Incorrect use of POS 11 can lead to claim denials or audits. - Modifier interactions
In some cases (for example telehealth), POS 11 might be used along with certain modifiers—but rules vary by payer. - Impact on patient cost sharing
Co-payments/deductibles might differ depending on place of service, so POS 11 vs POS 22 may affect what the patient owes.
Common Mistakes & Pitfalls with POS 11
- Assuming every “office” visit is POS 11
Some clinics are hospital-owned or part of hospital outpatient services and must use POS 22. - Using POS 11 for telehealth incorrectly
Some payers mandate POS 02 (telehealth) rather than POS 11, depending on the situation. - Failing to document location properly
If medical record doesn’t clearly show the service was at the provider’s office, the claim may be questioned. - Automatic defaulting
Billing systems sometimes default to POS 11 — staff must review to ensure correctness. - Mixing sites under same Tax ID
If a provider bills both hospital-based and office-based services under one entity, misclassification is more likely.
Best Practices for Using POS 11
- Maintain current documentation
Always note in the record the location of service (which office, what address). - Train your billing and clinical staff
Make sure everyone understands the criteria for POS 11 vs others. - Regular audits
Periodically review closed claims to ensure POS codes were correctly applied. - Stay updated with payer policies
Each insurer (including Medicare) may have nuances in how they treat POS codes and modifiers. - Use your EHR wisely
If your electronic health record or practice management system allows, lock or prompt POS code choices based on location data. - Clarify ownership/lease structure when affiliating
If your practice leases space inside hospitals, confirm whether POS 11 is still permitted under payer contracts.
Example Scenarios: POS 11 vs Not
- Correct (POS 11):
A dermatologist in a private clinic building (not hospital-affiliated) sees a patient for a mole removal. The visit is billed with POS 11. - Incorrect (should not use POS 11):
The same dermatologist practices in a hospital outpatient clinic — even though it feels like an office, it’s hospital-owned. In that case, POS 22 is correct. - Gray Area:
A physician group rents office space in a hospital building but bills independently. You must verify payer contracts and ownership to decide correct code.
Summary & Key Takeaways
- Place of Service 11 is used when healthcare services are delivered in a physician’s office or independent clinic—not in a hospital or institutional facility.
- Proper use of POS 11 affects reimbursement, claim acceptance, and audit risk.
- Always check the ownership structure, service setting, and payer rules to ensure POS 11 is valid.
- Avoid common mistakes by training, documentation, audits, and system safeguards.