POS 19 — Off-Campus Outpatient Hospital: Place of Service Code Explained

POS 19: What It Identifies

POS 19 identifies hospital outpatient department services at a location AWAY from the main hospital campus — the provider-based clinics hospitals operate across town. It exists (since 2016) largely because Medicare pays many off-campus departments differently under site-neutrality rules, making this code a payment-policy battleground.

The policy history matters here more than for most POS codes: Congress passed Section 603 of the Bipartisan Budget Act of 2015 specifically to close a payment gap where hospitals were acquiring physician practices and billing the exact same services at higher hospital outpatient rates simply by changing the POS code, with no change in the actual care delivered. POS 19 is now the marker CMS uses to apply reduced, more office-like payment rates to most new off-campus departments — while older, "grandfathered" off-campus departments established before November 2015 can still draw the higher outpatient rate. Knowing which category a given location falls into is essential to predicting payment correctly.

Use POS 19 For

Services at hospital-owned clinics located off the main campus that hold provider-based status
Physician services delivered in those departments (professional claim carries POS 19)
Hospital outpatient services at satellite locations more than 250 yards from the main buildings

Don't Use It For

Independent physician offices — POS 11, even if physically near a hospital
Departments on or adjacent to the main campus — POS 22
ASCs (POS 24), which are a different animal entirely

How POS 19 Affects Payment

POS 19 signals the facility rate on the professional claim, with the hospital billing its own facility fee — and for Medicare, many off-campus departments are paid site-neutrally (closer to office rates) under Section 603 rules. It's also the code that tells patients' plans a facility fee is coming, a growing source of patient complaints practices should anticipate.

Common POS 19 Billing Errors

Newly acquired practices billing POS 11 after conversion to provider-based status — the flagship POS compliance risk
Confusing 19 (off-campus) with 22 (on-campus) — payment rules differ under site neutrality
Failing to warn patients about facility fees, generating billing disputes the front desk inherits

Documentation That Supports POS 19

Because provider-based status carries real financial consequences (both for the hospital and the patient's out-of-pocket cost via the facility fee), CMS requires hospitals to maintain formal provider-based attestations for these locations, and billing staff should have access to that attestation record — including whether the department is grandfathered or subject to site-neutral payment — rather than relying on assumptions about a location's status. When a physician group is acquired or a new off-campus department opens, confirm the provider-based determination in writing before the first claim goes out, not after a payer flags a pattern.

Real-World Scenario

A hospital system opens a new cardiology clinic three miles from its main campus in 2024. Because this location was established well after the November 2015 cutoff, it's subject to site-neutral payment under Section 603 — Medicare pays many of its outpatient services closer to the office rate, not the higher traditional hospital outpatient rate. A billing team that assumes "hospital-owned equals higher facility payment" across the board, without checking the site-neutrality status of this specific newer location, will be surprised by lower-than-expected reimbursement and may misdiagnose it as a payer error rather than the correct application of policy.

Related POS Codes

POS 22 — On-campus outpatient POS 11 — Office POS 24 — ASC

← Back to the full POS code reference

Reviewed by Hassan Raza Awan, Founder — 4+ years of hands-on U.S. medical billing experience. General billing information — verify against current CMS guidance and your payer contracts.

Frequently Asked Questions

Why do patients get two bills from POS 19 locations?

Provider-based departments split billing: the professional claim (physician work) and the facility claim (hospital overhead). Patients used to single office bills see the facility fee as a surprise charge. Practices that explain this at scheduling save their front desks a lot of hard conversations.

Our hospital bought a practice across town. POS 19 or 22?

If it operates as a provider-based department off the main campus, POS 19 on professional claims. If the location is on or within 250 yards of the main campus, POS 22. The designation paperwork the hospital filed determines it — get that answer in writing from compliance, not from habit.

What is site-neutral payment and how does it affect POS 19?

Site-neutral payment means Medicare pays certain off-campus hospital outpatient services at rates closer to the office (non-facility) level instead of the higher traditional hospital outpatient rate. It generally applies to off-campus departments established after November 2015, so a location's opening date directly affects what POS 19 claims from that site actually pay.

Does POS 19 apply the same way to all payers, not just Medicare?

No — site-neutrality and facility-fee billing rules are largely Medicare-specific policy. Commercial payers negotiate their own facility fee and provider-based terms by contract, so a POS 19 location's commercial payment can differ substantially from its Medicare payment for the identical service.

POS 19: Off-Campus Outpatient Hospital