POS 11: Office
POS 11 is the place of service code for a physician office: a freestanding location where providers routinely examine, diagnose, and treat patients on an ambulatory basis. It pays the higher Medicare non-facility rate, which is why hospital-owned clinics billing POS 11 instead of 19 or 22 is a top audit target.
- Setting
- Freestanding physician office
- Rate type
- Non-facility (higher payment)
- Common pairing
- E/M 99202-99215, in-office procedures
- Watch out for
- Hospital-owned clinics: usually POS 19 or 22, not 11
What does POS 11 mean?
POS 11 identifies a physician office: per CMS, a location other than a hospital, SNF, military treatment facility, community health center, state or local public health clinic, or intermediate care facility, where the health professional routinely provides examinations, diagnosis, and treatment on an ambulatory basis.
It is the workhorse of professional billing; the large majority of CMS-1500 claims in a typical independent practice carry POS 11. The full code set is in our Place of Service reference, and the umbrella explanation of why POS moves money is in the POS overview.
When do you use POS 11?
Use POS 11 for services rendered face-to-face in a freestanding office your practice owns or leases: E/M visits, in-office procedures, injections, minor surgery, labs drawn in your own draw station. The test is the enrollment status of the location, not its appearance. A suite inside a medical office building on a hospital campus can still be POS 11 if the practice is independent; a cozy storefront clinic can be POS 22 if the hospital converted it to provider-based status.
How does POS 11 affect payment?
POS 11 pays the Medicare non-facility rate, the higher of the two Physician Fee Schedule rates, because the practice expense RVUs assume you pay for the staff, space, and supplies. In 2026 the national average for 99214 is about $135.61 at POS 11 versus roughly $84.50 at facility POS codes, before locality adjustment.
The gap is even wider on procedures with big supply costs; office-based procedures carry substantial practice expense that vanishes at the facility rate. Model your top 20 codes at both rates with the Medicare fee calculator before you sign any hospital alignment deal, because converting a POS 11 practice to provider-based billing reshuffles who gets that money.
What are the common POS 11 errors and denials?
POS 11 rarely denies; it overpays or underpays quietly, which is worse. The claim-level errors to watch:
- CARC 5 (procedure inconsistent with POS): facility-only codes like inpatient E/M 99231-99233 billed with POS 11. Check any confusing remit in the denial code lookup.
- Provider-based miscoding: billing POS 11 from a hospital-owned clinic. It pays more upfront and becomes an overpayment liability later.
- Split sites: a provider who works mornings at the freestanding office and afternoons at the hospital clinic needs claims split by actual location, not defaulted to their "home" POS.
- Telehealth defaulted to 11: quietly noncompliant for Medicare even when it pays.
Frequently asked questions
Ownership and enrollment decide it, not the sign on the door. If the practice location is enrolled as part of a hospital (provider-based), visits belong on POS 22 on campus or POS 19 off campus, and the hospital bills a facility fee separately. If it is a freestanding physician practice, it is POS 11. Ask whether the site is provider-based before you bill a single claim from a newly acquired location.
On the professional claim, yes. POS 11 pays the Medicare non-facility rate, which includes practice expense RVUs for overhead. POS 19 and 22 pay the professional the lower facility rate, though the hospital bills its own facility fee. For a 2026 99214 the difference is roughly $135.61 versus $84.50 nationally on the professional side.
For Medicare, no. Telehealth POS follows the patient: POS 10 if the patient is home, POS 02 otherwise, regardless of where the provider sits. A few commercial payers historically asked for POS 11 with modifier 95 to pay telehealth at parity, so check contracts, but never apply that convention to Medicare claims.
You get overpaid at the non-facility rate while the hospital also bills a facility fee, and that combination is exactly what OIG and MAC data mining looks for. Expect overpayment demands going back years, and remember the 60-day rule: once you identify the overpayment, you have 60 days to report and return it.
Sources & further reading
Reviewed by the ImmediCare Solutions RCM team
Certified billers and coders handling claims across 50+ specialties nationwide. This entry is reviewed against current payer policy and CMS rules. Last review: Jul 5, 2026.
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