Pam Warren, MHA, COC, CPC, Fellow

We’ve all seen that two-page chart in the CPT® book that indicates the place of service code (POS) that is expected to be reported for physician services. But not every physician performs in office settings; not all physicians perform office visits, and some services can be billed by physicians when they do not see the patient at all. This is when those POS codes can get tricky. I’ll try to walk us through the more confusing ones.

Place of Service Office

Place of Service Code 11 is for medical practice services in an office setting. When is a practice not an office? When it is considered a hospital outpatient department, such as with provider-based departments/practices. If you are responsible for provider-based coding and billing, know that both 19 and 22 should be used for ‘office-type’ services such as E/M and minor procedures performed in those settings, for government payers and Medicare Advantage plans. What’s the difference between 19 and 22, you ask? POS 19 is a location “off campus” and not immediately adjacent to or in the main hospital building, which is POS 22.

Place of Service Hospital

What about a physician hospital service when providers see patients in beds? Technically, a hospital admission (inpatient or observation) does not start until the order is placed, so the POS may reflect a different POS at the time the patient is seen.

For example, if the patient is treated in the emergency room by an ED provider, the POS code (23) will reflect an ED visit, even if the patient is admitted later in the day to observation by another provider. If a status change takes place at the hospital during the patient’s stay; for example, a patient is admitted to observation and later it is determined that an inpatient status is medically appropriate, the entire hospital stay is rolled up to inpatient. That is the rule for the facility billing, but for physicians, the POS at the time of the visit is what is billed. It may be observation (POS 22) at noontime, but later that day change to inpatient (POS 21). If the professional service is performed in the observation setting, it would not be appropriate to bill the inpatient setting on the professional claim.

“The correct POS for the claim is determined by the patient’s location in the facility at the time of the service” – NGS Medicare, Observation Services FAQ.