Place of service code (POS code) 22 stands for On-Campus Outpatient Hospital.
CMS defines POS 22 as “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.”
You enter the code in Item 24B of the CMS-1500 form (or the 837P electronic equivalent). It tells the payer two things at once: the service happened in a hospital outpatient department, and the patient was registered as an outpatient, not admitted.
Before January 1, 2016, POS 22 was simply called “Outpatient Hospital.” CMS revised the description to “On Campus-Outpatient Hospital” and created POS 19 for off-campus departments.
The change came from Section 603 of the Bipartisan Budget Act of 2015, which targeted higher payments for new off-campus provider-based clinics.
This guide breaks down what POS 22 means, when to use it, how it differs from POS 11 and 19, and how to avoid the denials that follow misuse.
When Should You Use POS 22?
Use POS 22 when all four conditions are met:
- The service happened in a hospital-owned outpatient department.
- That department sits on the hospital’s main campus, within 250 yards of the main buildings.
- The patient was registered as a hospital outpatient.
- The patient was not formally admitted as an inpatient.
Qualifying Service Locations
Hospital-owned outpatient clinics, provider-based departments, and on-campus specialty centers all qualify if they meet the campus boundary. Buildings connected by covered walkways, bridges, or tunnels still count as on-campus.
Common Services Billed Under POS 22
Below are the common services billed under POS 22:
- Outpatient diagnostic imaging (MRI, CT, ultrasound)
- Same-day surgical procedures (colonoscopy, biopsy, joint injection)
- Infusions and chemotherapy
- Pre-operative consults at hospital-run clinics
- Wound care and physical therapy in hospital outpatient departments
- Hospital-based observation services (when not coded as inpatient)
Check three things before coding: who owns the clinic, where it physically sits, and how the patient was registered. Ownership records live in PECOS (Provider Enrollment, Chain, and Ownership System). The address on the claim must match the PECOS address exactly.
POS 11 vs POS 22 vs POS 19: What Are the Key Differences?
POS 11, POS 22, and POS 19 are commonly used place of service codes in medical billing, but they apply to different healthcare settings. POS 11 is used for independent physician offices, while POS 22 and POS 19 apply to hospital-owned outpatient departments. The biggest difference between POS 22 and POS 19 is whether the facility is located within or beyond 250 yards of the main hospital campus.
The comparison below breaks down the key differences in ownership, location, billing, reimbursement, and modifier requirements.
| Factor | POS 11 | POS 22 | POS 19 |
| Setting | Physician office | On-campus hospital outpatient | Off-campus hospital outpatient |
| Ownership | Physician/group | Hospital | Hospital |
| Location | Any office | Within 250 yards of the hospital | Beyond 250 yards |
| Payment Rate | Non-facility (higher) | Facility (lower) | Facility/PFS-equivalent |
| Claim Forms | CMS-1500 | CMS-1500 + UB-04 | CMS-1500 + UB-04 |
| Facility Fee | No | Yes | Yes |
| PO/PN Modifiers | No | No | Yes (UB-04 only) |
| Common Confusion | Mistaken for a hospital clinic | Confused with POS 19 | Mistaken as POS 22 |
How Does Split Billing Work in POS 22?
POS 22 split billing works by separating the professional services from the facility services into two different claims.
In an on-campus outpatient hospital setting, both the physician and the hospital bill Medicare or the insurance payer separately for the care provided during the same visit.
The physician submits a CMS-1500 claim under their individual NPI for services they personally performed, such as evaluation, medical decision-making, and procedures. These services are reimbursed under the Physician Fee Schedule (PFS) facility rate.
At the same time, the hospital submits a UB-04 claim under the hospital’s NPI for the operational and facility-related costs associated with the visit. This includes the exam room, equipment, nursing staff, medications, and supplies. Hospital outpatient services are typically reimbursed through the Outpatient Prospective Payment System (OPPS) using Ambulatory Payment Classification (APC) codes.
For the payer to process both claims correctly, the physician claim and hospital claim must match on key details, including:
- Date of service
- Patient identifiers
- Location of care
- Related procedures or services
If the information does not align, the payer may delay, deny, or suspend one or both claims for review.
Does POS 22 Affect CPT Coding?
POS 22 does not change which CPT code you select. It changes how that CPT code is paid.
- Same CPT, Different POS: CPT codes describe the work done. POS describes where the work happened. The same office visit code (99213, 99214) can sit on a POS 11 or POS 22 claim. The CPT stays the same; the payment shifts.
- E/M Coding in Outpatient Hospital Settings: Hospital outpatient E/M visits use the same office or other outpatient codes (99202–99215). The physician documents the same elements: history, exam, and medical decision-making (or time). The facility setting does not bump the level of service.
- Modifier Use With POS 22: Most POS 22 professional claims need no special modifiers. The PO and PN modifiers belong on the hospital’s UB-04, not the CMS-1500. Standard modifiers (25, 59, 76, etc.) apply normally.
How Do Different Payers Handle POS 22?
Each payer reads POS 22 the same way at a basic level: it is a facility setting. The rules around payment and modifiers vary.
Medicare
Medicare pays POS 22 claims at the facility rate under the PFS. The hospital files a UB-04 under OPPS. Both halves follow the rate methodology in the Medicare Claims Processing Manual, Chapter 26.
Medicaid
Medicaid rules vary by state. Some states mirror Medicare exactly. Others require extra documentation linking the physician and hospital, set their own facility-fee rules, or restrict which on-campus locations qualify. Always check the state Medicaid manual before coding.
Commercial Payers
Commercial plans build their own contracts. Most follow CMS conventions, but reimbursement amounts are based on contracted rates, not the PFS. Some Medicare Advantage plans treat POS 19 and POS 22 differently. Read each contract for the exact policy.
6 Common POS 22 Billing Errors That Cause Denials
These are the mistakes that fill denial queues. Each one is preventable with a clear coding workflow.
- Using POS 11 for Hospital-Owned Clinics: This is the costliest error. The physician collects the higher non-facility rate while the hospital files a separate facility claim. Payers flag the combination. CMS treats it as a payment integrity issue, not a paperwork slip.
- Confusing POS 19 and POS 22: Billing POS 22 for an off-campus location across the street triggers takebacks once the payer audits the address. Always verify the distance against the main campus.
- Using POS 22 for Inpatient Stays: If the patient has a formal admission order, POS 21 applies. POS 22 on an inpatient claim is a clear documentation mismatch.
- Missing or Incorrect Modifiers on the Facility Claim: The PO and PN modifiers belong on UB-04 lines for off-campus departments. Forgetting them on POS 19 facility claims causes denials. Adding them to POS 22 claims does the same.
- POS Mismatch With Documentation: The chart note says the visit happened in the hospital-based clinic; the claim says POS 11. Auditors catch this in record reviews. Documentation and POS must agree.
- Assuming POS 22 Pays More Than POS 11: It does not. The physician’s portion is lower under POS 22. Total Medicare spending may be higher because of the facility fee, but that money goes to the hospital, not the physician.
What Form Should Be Used for POS 22 Billing?
POS 22 always involves two forms.
- CMS-1500 for Professional Claims: The physician submits a CMS-1500 (or 837P electronic) under the physician’s NPI. POS 22 goes in Item 24B for each line.
- UB-04 for Facility Claims: The hospital submits a UB-04 (or 837I electronic) under the hospital’s NPI for the facility portion. This claim runs through OPPS using APC codes.
- Documentation That Must Match: The medical record must show the actual location, the patient’s outpatient registration status, and the services rendered. Any of these missing or contradictory items is an audit red flag.
Billing Checklist for POS 22
Before you submit, run through this list.
- Service location is on the hospital’s main campus (within 250 yards).
- The facility is hospital-owned and registered in PECOS.
- The patient was registered as a hospital outpatient.
- Patient has no formal admission order.
- CMS-1500 Item 24B contains POS 22.
- The hospital is filing the matching UB-04.
- Date of service and patient identifiers match across both claims.
- Documentation supports the location and service.
- No PO or PN modifier on the professional claim (those belong on UB-04 for off-campus only).
- Fee schedule check: facility rate applied, not non-facility rate.
Final Words
POS 22 is short, but it carries weight. One wrong digit can shift a claim from paid to denied, or from clean to audited. The rule is simple: hospital-owned plus on-campus plus outpatient equals POS 22. Verify the address, match the documentation, and remember that the physician’s share is smaller in this setting because the hospital files its own facility claim. Build the checks into your workflow, and the denials drop.
