Place of Service POS 11 in medical billing refers to services provided within the vicinity of a physician’s office, and these services are reported in CMS-1500 Box 24B. While POS codes appear to be simple, the reimbursement methodology depends upon their correct usage.
POS codes affect the audit exposure and payer compliance for POS 11 non-facility rates. Non-facility reimbursement rates are typically higher than facility-based payments. Any intentional or unintentional incorrect reporting in POS 11 codes can result in overpayments, compliance findings, or recoupments. For accurate claim submissions in 2026, understanding the applications of POS 11 is essential.
What is the Place of Service 11?
Description of Place of Service
As per CMS place of service 11, POS is defined as
| A location, other than a hospital or facility, where the health professional routinely provides health examinations, diagnoses, and treatment on an ambulatory basis. |
The qualifying office settings are
- Private practices owned by physicians
- Group medical offices
- Non-hospitals and non-provider-based clinics
Ultimately, the POS classification is based upon ownership and billing structure.
The Financial Impact: Non-Facility Reimbursement Rates
Why POS 11 Pays More Than Hospital Settings
POS is reimbursed under the non-facility reimbursement rates. CMS assumes that the provider bears the overhead practice costs, including office supplies, rent, and staff payments.
Non-facility reimbursement is a payment methodology of Medicare in which the expense component of a practice is entirely paid to the provider, rather than being split between a professional fee and a separate facility payment.
Payment Structure Breakdown:
- Professional fee paid to the provider
- The facility fee is non-applicable under POS 11
Hospital-based POS codes split reimbursements between the provider and the facility, while providers operating in an office setting bear full operational responsibility, so CMS applies a higher relative value unit (RVU) payment under POS 11. Misreporting POS 11 raises audit risks and inflates the reimbursements.
POS 11 Head-to-Head Comparisons
POS 11 vs Other Common Place of Service Codes
| POS Code | Description | Ownership Model | Reimbursement Type |
| POS 11 | Office | Non-facility rate | Non facility rate |
| POS 22 | Outpatient hospital | Hospital-owned | Facility rate |
| POS 12 | Home | Patient location | Non-facility (context-specific) |
| POS 49 | Independent clinic | Clinic owned | Facility rate |
Provider-based clinic rule:
If a clinic meets CMS provider-based criteria, then POS 22 is applied regardless of its physical separation from the provider.
Telehealth Rules Update for 2026
Telehealth POS Changes: POS 10 vs POS 11
During the COVID-19 public health emergency, CMS temporarily permitted using POS 11 for telehealth services to maintain payment parity. This flexibility was not permanent, and now this exception has been phased out by CMS.
Now in 2026, CMS expects telehealth services to be reported using:
- POS 10- patient at home
- POS 11 patient not at home
Using POS 11 for virtual visits in 2026 may result in overpayment reviews or payment audits, unless it is explicitly allowed by payer policy.
Common Audit Red Flags
POS 11 Audit Risks to Watch
- Location Mismatch: If a claim is listed as an office visit, but the address or NPI belongs to a hospital facility.
- Invalid CPT Codes: Facility-only CPT codes are coding explicitly billed when using a non-facility POS code
- Misclassification Telehealth: Telehealth encounters are clearly identified and submitted as in-office visits
- Documentation vs Billing: Documentation indicating facility resources were used while charging higher non-facility rates
- Scheduling Inconsistencies: The POS code on the claim must perfectly match the scheduling and registration records
Conclusion: Using POS 11 Correctly in 2026
At present, in 2026, Place of Service (POS) remains bound to true office-based and non-facility settings. In contrast, it is true that POS 11 yields higher reimbursement rates; practices’ Place of Service (POS) 11 coding decisions should be based on compliance rather than on profit potential.
Practices need to verify how the service was delivered, whether in person or virtual, clearly understand payer-specific rules, and confirm the practice’s ownership structure to correctly report POS. Consistently applying these rules is one way to protect practices from audits, denials, and repayment demands.
Resources
- US Department of Health & Human Services. Telehealth. Accessed January 9, 2026. https://telehealth.hhs.gov
- American Health Information Management Association. Coding, compliance, and revenue cycle. Accessed January 9, 2026. https://bok.ahima.org/topics/coding-compliance-and-revenue-cycle/
- Palmetto GBA. Telehealth billing and G-code requirements. Accessed January 9, 2026. https://palmettogba.com/JMHHH/did/VMCTLPL2JJ
About the Author
Laim Will is a medical billing and coding content writer with 5 years of practical experience in Revenue Cycle Management (RCM). She specializes in creating beginner-friendly medical billing guides, denial management explanations, coding basics, and AR workflow insights. Her content is designed to simplify complex billing processes using real-world industry knowledge and clear explanations.
