POS 32 is the Place of Service code used to bill professional services provided to residents of a Nursing Facility (NF) when Medicare Skilled Nursing Facility Part A coverage does not apply.

CMS defines POS 32 as “a facility which primarily provides to residents skilled nursing care and related services for the rehabilitation of injured, disabled, or sick persons, or, regularly, health-related care services above the level of custodial care to other than individuals with intellectual disabilities.”

POS code 32 sits within the nursing and residential care family of POS codes, alongside POS 31 (Skilled Nursing Facility), POS 33 (Custodial Care Facility), POS 13 (Assisted Living Facility), and POS 54 (Intermediate Care Facility for Individuals with Intellectual Disabilities).

This guide explains when to use POS 32, how it differs from POS 31, Medicare Part A coverage rules, documentation requirements, CPT coding, telehealth, and CMS billing guidance.

When Is POS 32 Used?

POS 32 is used when a physician or qualified non-physician practitioner furnishes a service to:

A patient in a Nursing Facility.
A patient in a Skilled Nursing Facility who has exhausted Part A coverage.
A patient in an SNF stay that is not covered under Part A (for example, a stay without a qualifying three-day prior inpatient hospital admission).

The patient’s Medicare Part A coverage status on the date of service determines whether POS 31 or POS 32 applies. CMS instructs that for services in mixed facilities containing both NF and SNF settings, POS 31 is used unless the physician can verify that no Part A payment will be made.

CPT codes commonly reported with POS 32 include initial nursing facility care (99304, 99305, 99306), subsequent nursing facility care (99307, 99308, 99309, 99310), discharge management (99315, 99316), and the Medicare prolonged service code G0317 when paired with 99306 or 99310.

POS 31 vs. POS 32: What Is the Difference?

The difference between POS 31 and POS 32 is the patient’s Medicare Part A coverage status on the date of service. The building does not determine the code. The coverage does.

Element	POS 31 (SNF)	POS 32 (NF)
Facility description	Skilled Nursing Facility	Nursing Facility (or SNF without Part A)
Patient coverage status	Active Medicare Part A SNF stay	NF resident, exhausted Part A, or non-covered SNF stay
Facility payment	Yes, under SNF PPS to the facility	No SNF PPS payment to the facility
Physician PE RVU classification	Facility	Non-facility
Common CPT pairings	99304-99310, 99315-99316, G0317	99304-99310, 99315-99316, G0317
MM13767 edit	No conflict	Rejected or adjusted if the date overlaps a paid Part A SNF claim

How Is the Choice Between POS 31 and POS 32 Determined?

The choice is determined by Medicare Part A coverage status on the date of service. CMS guidance in MM13767 lists three coverage scenarios:

Patient in an SNF with active Part A coverage: POS 31
Patient in an NF or in an SNF without Part A coverage: POS 32
Patient in a mixed facility: POS 31 unless the physician verifies no Part A payment will be made.

Under Medicare rules, an SNF Part A benefit period requires a qualifying three consecutive days of inpatient hospital stay within 30 days of admission. It provides up to 100 days of coverage per spell of illness. Days beyond 100 in a spell convert the patient’s status from a Part A SNF stay to a long-term NF stay, which moves the POS from 31 to 32.

What Documentation Appears on a POS 32 Claim?

A POS 32 claim line includes the date of service, the place of service code 32, the CPT or HCPCS code, any applicable modifiers, the diagnosis code linkage, units, charges, and the rendering provider’s NPI.

The supporting medical record contains the date and place of the encounter, the patient’s presenting problems, history, and exam to the extent the code descriptor requires, medical decision making or total time on the date of the encounter, the assessment and plan, and the practitioner’s signature with date.

Time-based E/M coding under the 2023 CPT revisions requires documentation of total time on the date of encounter. Prolonged service code G0317 is reported when the total time exceeds the base code (99306 or 99310) by 15 or more minutes.

Can POS 32 Be Used for Telehealth Services?

No, POS 32 can’t be used for Telehealth Services as it is not a telehealth POS code. Telehealth services use a separate POS code set under Medicare rules.

CMS established two telehealth POS codes:

POS 02: Telehealth provided in a location other than the patient’s home
POS 10: Telehealth provided in the patient’s home

Under Medicare rules, POS 02 generally pays at the facility rate, and POS 10 generally pays at the non-facility rate. Modifier 95 indicates synchronous audio-video telehealth. Modifier 93 indicates audio-only telehealth.

Which CPT Codes Are Commonly Billed With POS 32?

The Evaluation and Management (E/M) code family for nursing facility services includes several CPT codes commonly reported with POS 32 for dates of service on or after January 1, 2023:

CPT code	Description	Code selection basis
99304	Initial nursing facility care, straightforward or low MDM, or 25 minutes total time	MDM or time
99305	Initial nursing facility care, moderate MDM, or 35 minutes total time	MDM or time
99306	Initial nursing facility care, high MDM, or 45 minutes total time	MDM or time
99307	Subsequent nursing facility care, straightforward MDM, or 10 minutes total time	MDM or time
99308	Subsequent nursing facility care, low MDM, or 15 minutes total time	MDM or time
99309	Subsequent nursing facility care, moderate MDM, or 30 minutes total time	MDM or time
99310	Subsequent nursing facility care, high MDM, or 45 minutes total time	MDM or time
99315	Nursing facility discharge day management, 30 minutes or less	Time
99316	Nursing facility discharge day management, more than 30 minutes	Time
G0317	Prolonged nursing facility evaluation and management services, each additional 15 minutes	Time (Medicare-specific; used with 99306 or 99310)

CPT 99318 (annual nursing facility assessment) was deleted effective January 1, 2023. The annual federally mandated visit is now reported using the subsequent nursing facility care codes 99307-99310.

Documentation That Appears in a POS 32 Medical Record

A POS 32 service record typically contains:

Date and place of the encounter.
Patient identifiers and Medicare Beneficiary Identifier.
Reason for the visit and chief complaint or interval history.
History and exam to the extent the code descriptor requires.
Medical decision-making elements, or the total time spent on the date of the encounter.
Diagnoses addressed and assessment.
Plan of care, including medications, orders, and follow-up.
Signature and credentials of the rendering practitioner, with date.

For time-based E/M codes, the record shows total time spent on activities on the date of the encounter, including review of records, examination, counseling, ordering tests, documenting in the record, and care coordination.

Final Words

POS 32 reports physician services in a Nursing Facility or in an SNF where the patient has no Part A coverage on the date of service. The code pays at the non-facility rate, which is why CMS audits and the MM13767 edits target practices that default to POS 32 without verifying Part A status.

Accurate POS 32 reporting protects revenue on both sides: it prevents recoupments from incorrect non-facility payments during Part A stays, and it prevents underpayments from defaulting to POS 31 after Part A exhaustion. A consistent eligibility-driven workflow, a hard edit at the point of charge entry, and quarterly POS audits cover most of the risk.