Understanding POS 22 in Medical Billing: Expert Guide for Accurate Claims
In medical billing, coding accuracy directly affects reimbursement, compliance, and the overall revenue cycle. Place of Service (POS) codes are a key part of that accuracy, telling payers where a service took place. One code that often causes confusion is POS 22. Errors in using this code can cause claim denials, delayed payments, or even payer audits.
What POS 22 Means
POS 22 stands for “On-Campus Outpatient Hospital.” It is used for services provided to a patient in a hospital’s outpatient department located on the main campus, where the patient does not require an overnight stay. The location must be both owned and operated by the hospital.
While the patient is physically in the hospital environment, this setting is considered outpatient because the care does not involve admission. This distinction is critical for billing, as it determines how both the provider and facility are reimbursed.
Why Correct POS 22 Usage Matters
Accurate POS coding ensures claims are processed correctly the first time. When POS 22 is used appropriately, the claim reflects a hospital-based outpatient service, which triggers facility-based reimbursement. In this model, the provider’s professional payment is lower compared to non-facility settings like POS 11 (office), because the hospital separately bills for facility-related expenses.
Facility vs. Non-Facility Reimbursement
In facility settings like POS 22, the hospital bears the costs of maintaining the space, providing support staff, and operating medical equipment. The professional claim covers the provider’s work, while the facility claim covers the hospital’s resources. In non-facility settings such as POS 11, the provider’s payment rate is higher because they bear these costs themselves.
Split Billing in POS 22
POS 22 claims often require split billing:
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The provider submits a professional claim for services performed.
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The hospital submits a facility claim for operational costs.
Both claims must be coordinated so that procedure codes, dates of service, and patient information match exactly. Inconsistent claim data can result in payer rejections or underpayments.
How POS 22 Compares to Other POS Codes
| POS Code | Setting Description | Inpatient or Outpatient | Ownership / Location |
|---|---|---|---|
| 11 | Independent provider office or clinic | Outpatient | Provider-owned, off hospital campus |
| 21 | Hospital inpatient stay | Inpatient | Hospital-controlled inpatient care |
| 22 | On-campus outpatient hospital | Outpatient | Hospital-owned department on the main campus |
| 19 | Off-campus outpatient hospital department | Outpatient | Hospital-owned but located off main campus |
Real-World Workflow Example
Imagine a patient visiting the hospital’s main campus outpatient cardiology clinic for an echocardiogram. The test is completed, and the patient goes home the same day. In this situation:
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The cardiologist bills for interpreting the echocardiogram using POS 22.
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The hospital submits a separate facility claim for the space, nursing support, and diagnostic equipment used.
If the same cardiology clinic were independently owned and operated—even if located within the hospital building—the correct POS code would be POS 11, not POS 22.
Common Mistakes with POS 22
Using POS 11 When POS 22 Applies
This happens when staff focus on the physical location without considering ownership and operational control. If the hospital owns and operates the department, POS 22 should be used.
Confusing On-Campus with Off-Campus
Services delivered more than approximately 250 yards from the main hospital building are generally considered off-campus outpatient and require POS 19.
Using POS 22 for Inpatient Services
If the patient has been admitted, inpatient POS 21 applies, even if services are rendered in the same physical space.
Best Practices for Accurate POS 22 Billing
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Educate Staff Regularly – Ensure everyone involved in scheduling, check-in, and billing understands POS rules.
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Maintain Location Records – Keep updated documentation listing all departments and whether they qualify as on-campus or off-campus.
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Incorporate Location Checks in Workflows – Verify location and ownership before claim submission.
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Document Precisely in the EHR – Record the service location in patient encounter notes.
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Audit Claims Periodically – Review submitted claims for coding accuracy to prevent systemic errors.
Quick Decision Guide for POS Selection
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Admitted to hospital → POS 21
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Outpatient, on-campus, hospital-owned → POS 22
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Outpatient, hospital-owned, off-campus → POS 19
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Independent office → POS 11
Importance for Medicare Claims
Medicare strictly enforces POS accuracy. Because payment rates differ significantly between facility and non-facility settings, incorrect coding can cause overpayments or underpayments. Overpayments often lead to repayment requests or post-payment audits, while underpayments affect revenue flow.
Extended FAQ on POS 22
When should POS 22 be used?
It should be used for services provided in a hospital-owned outpatient department located on the hospital’s main campus, when the patient is not admitted.
Do I need split billing for POS 22?
Yes, in most cases. The provider submits the professional claim, and the hospital submits the facility claim.
What is the difference between POS 22 and POS 19?
POS 22 is for on-campus hospital outpatient departments. POS 19 is for hospital-owned outpatient departments located off-campus, typically more than 250 yards from the main hospital buildings.
What happens if I use the wrong POS code?
Incorrect codes can lead to claim denials, reduced payments, overpayments with repayment demands, or audits.
How can I avoid POS coding mistakes?
Train staff, verify location ownership, maintain updated facility records, and perform regular audits.
Does POS 22 affect commercial insurance claims?
Yes. While policies vary, most commercial payers follow similar facility vs. non-facility reimbursement models, so correct coding is essential.
Can POS 22 be used for telehealth?
POS 22 is location-based and typically not used for telehealth services, which require their own specific POS codes unless payer-specific rules apply.
What if a clinic is leased inside the hospital?
If the clinic is independently owned and operated, POS 11 applies, even if it is physically in the hospital building.
How can I confirm if my department qualifies as POS 22?
Check with hospital administration for ownership and operational control details. Compare against CMS definitions to ensure compliance.
Does POS 22 ever apply to emergency department visits?
No. Emergency departments have their own POS code (23) and should not be billed under POS 22.
Summary
POS 22 identifies services performed in a hospital-owned outpatient department located on the hospital’s main campus. Correct use ensures accurate reimbursement and compliance with payer requirements. Misuse can result in payment delays, denials, or audit risk.
By combining staff education, updated facility documentation, clear workflows, and regular audits, healthcare organizations can ensure POS 22 is applied correctly every time. Accurate POS coding is not only a compliance requirement but also a vital part of protecting revenue and maintaining a smooth billing process.
For official definitions and updates, the Centers for Medicare & Medicaid Services provides reliable resources that support correct coding practices.