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Place of service (POS) codes identify where a service was delivered. They appear in the 837’s CLM05 composite and they affect payment, because the Medicare Physician Fee Schedule’s practice expense component differs between facility and non-facility settings. Maintained by CMS.1

Why POS affects payment

The practice expense RVU differs by setting. When a service is delivered in a facility, where the facility bears the overhead and bills separately, the professional payment is lower. When it is delivered in a non-facility setting like your office, the professional payment includes the practice expense. Using the wrong POS therefore either underpays you or creates an overpayment. Both matter; the second is the one that becomes a refund obligation.

The codes you’ll actually use

★ = the ones most MSO-PC groups use. Facility/non-facility designations and their payment consequences can change. Verify current designations against the CMS POS code set and the current fee schedule rather than relying on a static table — telehealth designations in particular have shifted repeatedly.

The telehealth trap

POS 02 vs POS 10 is the most common POS error in outpatient practice, and it has a payment consequence.
  • POS 02, telehealth provided other than in the patient’s home
  • POS 10, telehealth provided in the patient’s home
The distinction is about where the patient is, not where the clinician is. A patient at home is POS 10; a patient at an originating site clinic is POS 02. They carry different facility designations and therefore different payment. And payer policies on telehealth POS have changed repeatedly since 2020 — confirm current requirements per payer, because commercial payers do not all follow Medicare here. Modifier usage interacts with this too: modifier 95 identifies synchronous telemedicine. Some payers want POS 11 plus modifier 95 rather than POS 02 or 10. There is no universal answer; there is a per-payer answer.

The full list

The complete POS code set is published and maintained by CMS. Beyond the codes above, it includes settings for pharmacies, schools, homeless shelters, prisons, military treatment facilities, tribal facilities, hospices, psychiatric facilities, substance abuse treatment facilities, mass immunization centers, birthing centers, and others. Consult the CMS list for anything not in the table above.

Common failures

Audit your POS distribution quarterly. A practice that delivers only office and telehealth services should show POS 11 and 10 (or 02) almost exclusively. Anything else in the distribution is worth explaining.

Sources

  1. CMS, Place of Service Code Set. Facility/non-facility designations affect payment under the Medicare Physician Fee Schedule; see CMS, Physician Fee Schedule.