POS 19: Off Campus-Outpatient Hospital
POS 19 is the place of service code for a hospital outpatient department located off the main hospital campus, generally more than 250 yards from the main buildings. Professional claims with POS 19 pay the lower Medicare facility rate, and the code also drives site-neutral payment rules on the hospital side.
- Setting
- Hospital outpatient department, off campus
- Rate type
- Facility (lower professional payment)
- Common pairing
- Clinic E/M, infusion, imaging professional components
- Watch out for
- Billing POS 11 from a hospital-acquired clinic
What does POS 19 mean?
POS 19 identifies an off campus-outpatient hospital: per CMS, a portion of an off-campus hospital provider-based department that provides diagnostic, therapeutic, and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.
Plain English: a clinic, infusion suite, or imaging center that looks freestanding but is legally part of the hospital and sits away from the main campus. CMS added POS 19 in 2016 specifically to see where hospital outpatient care was happening, because Congress had just made off-campus location a payment issue. The full code set is in our Place of Service reference.
When do you use POS 19?
Use POS 19 on professional claims when the service was rendered at a hospital provider-based department located off the main campus, typically defined as beyond 250 yards from the main hospital buildings. Common examples:
- A hospital-owned multispecialty clinic in a strip mall across town.
- An off-campus infusion or wound care center operating under the hospital's enrollment.
- Formerly independent practices converted to provider-based departments after acquisition.
If the department is on campus, use POS 22. If the location is a freestanding physician office that was never converted to provider-based status, it stays POS 11. The enrollment paperwork, not the address on the sign, is the source of truth.
How does POS 19 affect payment?
On the professional claim, POS 19 pays the Medicare facility rate: lower than POS 11 because the practice expense component assumes the hospital carries the overhead and bills its own facility fee. The direction is always the same: professional payment down, total episode payment split across two claims.
POS 19 also feeds site-neutral payment policy. Since the Bipartisan Budget Act of 2015, many services at newer off-campus departments are paid at a reduced, PFS-equivalent rate on the hospital side rather than full OPPS. That is a hospital-claim issue, but the POS code on the professional claim is one of the data points CMS uses to police it. Compare your codes at both rates with the Medicare fee calculator before agreeing to any employment comp model based on collections, because a move from POS 11 to POS 19 cuts professional-side collections even when the provider's work is unchanged.
What are the common POS 19 errors and denials?
- POS 11 leakage: the most common and costly error. Acquired practices keep billing POS 11 from a converted location, collecting non-facility rates while the hospital bills facility fees. That is an overpayment pattern auditors search for by matching addresses.
- 19 vs 22 swaps: rarely deny, but they distort site-neutral payment on the hospital claim and show up in provider-based audits.
- CARC 5 (procedure inconsistent with POS) when office-only codes hit POS 19; check remits in the denial code lookup.
- Mismatched claims: professional claim says POS 19, hospital never files the corresponding facility claim, and the payer pends both for development.
Frequently asked questions
Both are hospital outpatient departments; the split is geography. POS 22 is on the main hospital campus or within roughly 250 yards of it. POS 19 is a provider-based department beyond that, like a hospital-owned clinic across town. Professional payment is the facility rate either way, but the distinction matters for the hospital's facility claim under site-neutral payment policies.
POS 19 triggers the Medicare facility rate, which removes most practice expense RVUs from the professional payment because the hospital is billing separately for the overhead. When a hospital acquires a practice and converts it to a provider-based department, the physician claim drops from the non-facility to the facility rate. The total dollars usually go up once the facility fee is added, but they shift to the hospital claim.
Often yes. Provider-based billing means the patient can owe coinsurance on two claims: the professional service and the hospital facility fee. The same visit at a freestanding POS 11 office generates one bill. This is the surprise-bill scenario patients complain about after their doctor's office is acquired, so front desks at POS 19 sites should explain the two-bill structure up front.
The hospital's provider-based attestation and enrollment records decide it, not the billing team's judgment. If the location is enrolled as an off-campus provider-based department, professional claims from that address use POS 19. Get the list of provider-based locations in writing from the hospital's enrollment or reimbursement department and keep it synced with your charge router.
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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