New and revised place of service codes for outpatient hospitals

Note: This article was revised December 9, 2015, to clarify the effective date of place of service (POS) 19. POS 19 will be accepted for any claims processed on or after January 1, 2016. That is, POS code 19 is valid for any claim, regardless of the date of service, when it is processed on or after January 1, 2016. The title of the table was also changed for clarification. All other information is unchanged.

** Revising the current place of service (POS) code set by adding new POS code 19 for “off campus-outpatient hospital” and revising POS code 22 from “outpatient
hospital” to “on campus-outpatient hospital;” and

** Making minor corrections to POS codes 17 (walk-in retail health clinic) and 26 (military treatment facility).

You should ensure that your billing staffs are aware of these POS code change

Therefore, in response to the discussion in the 2015 physician fee schedule (PFS) final rule with comment period published November 13, 2014 (79 FR 67572); in order to differentiate between on-campus and off-campus provider-based hospital departments, CMS is creating a new POS code (POS 19) and revising the current POS code description for outpatient hospital (POS 22).

CR 9231, from which this article is taken, provides this POS code update, effective January 1, 2016. Specifically, CR 9231 updates the current POS code set by adding
new POS code 19 for “off campus-outpatient hospital” and revising POS code 22 from “outpatient hospital” to “on campus-outpatient hospital” as described in the   following table.

Code Descriptor


POS 19 Off campusoutpatient hospital

A portion of an off-campus hospital provider based department which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.

POS 22 On campusoutpatient  hospital

A portion of a hospital’s main campus which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons
who do not require hospitalization or institutionalization.



Additional information related to POS codes 19 and 22

** Payments for services provided to outpatients who are later admitted as inpatients within three days (or, in the case of non-IPPS hospitals, one day) are bundled when the patient is seen in a wholly-owned or whollyoperated physician practice. The three-day payment window applies to diagnostic and nondiagnostic services that are clinically related to the reason for the patient’s inpatient admission, regardless of whether the inpatient and outpatient diagnoses are the same.

The three-day payment rule will also apply to services billed with POS code 19.

** Claims for covered services rendered in an off campus-outpatient hospital setting (or in an on campus-outpatient hospital setting, if payable by Medicare) will be paid at the facility rate. The payment  policies that currently apply to POS 22 will continue to apply to this POS, and will now also apply to POS 19 unless otherwise stated.

** Reporting outpatient hospital POS code 19 or 22 is a minimum requirement to trigger the facility payment amount under the PFS when services are provided to a registered outpatient. Therefore, you should use POS code 19 or POS code 22 when you furnish services to a hospital outpatient regardless of where the face-to-face encounter occurs.

** Your MACs will allow POS 19 to be billed for G0447 (Face-to-face behavioral counseling for obesity, 15 minutes) and G0473 (Face-to-face behavioral counseling for obesity, group (2-10), 30 minutes) in the same way as those services are billed with POS code 22

Reimbursement Guidelines
For clinic visits and services performed in the hospital outpatient setting, Moda Health does not allow split-billing of Provider-based clinic services as allowed by CMS for its Original Medicare business. This applies whether the clinic is located in an on campus-outpatient hospitalsetting (POS 22), or an off campus outpatient hospital (POS 19), and whether or not the clinic uses the hospital tax identification number. Do not split-bill clinic-based services, billing part of the service as a facility charge, and part of the service as a professional charge using POS 19 or 22 or a professional revenue code. All professional services provided in an outpatient clinic setting are to be billed on a CMS1500 claim form or electronic equivalent, using POS 11 Office. Professional claims will be reimbursed according to the applicable professional fee schedule.
Background Information
Facility fees, allowed by Medicare since 2000, have become increasingly common as more physician practices are sold to hospitals. Under the Medicare provider-based billing model, when a patient sees a physician who worksin an office building that is owned by the hospital, the hospital can charge the patient a facility fee for the use of the building in which the patient was seen. The facility fee charge is separate from the fee for the physician’s professional services. However, if the patient sees a physician at a clinic building owned by a physician group, clinic practice, or an independently owned physician office (e.g. soleproprietor office), then a separate facility fee may not be charged to the patient in addition to the physician charges.
Patients increasingly want to understand the charges associated with their care, and how these impact their financial responsibilities of deductibles, copayments, and coinsurance. As a result, patients have questions and concerns about these facility fee charges for physician visits, particularly when a clinic building was owned by a physician or clinic group and is subsequently bought by a hospital. Moda Health has developed this policy in response to member complaints and concerns