POS 32 — Nursing Facility (Custodial / Non-Part A): Place of Service Code Explained

POS 32: What It Identifies

POS 32 identifies physician services to nursing facility residents NOT in a Medicare Part A skilled stay — the long-term custodial population that makes up most nursing home residents. Freed from consolidated billing's grip, POS 32 billing is more straightforward — but carries its own E/M family and visit-frequency scrutiny.

Use POS 32 For

Visits to long-term custodial nursing home residents
Services after a patient's Part A benefit exhausts
Regular medical direction of chronic nursing facility patients

Don't Use It For

Part A skilled stays — POS 31 (and consolidated billing awareness)
Assisted living facilities — separate POS
Home care — POS 12

How POS 32 Affects Payment

Non-facility-style payment for the nursing facility E/M family (99304–99316), without Part A consolidated billing complications. Payer attention focuses on visit frequency and medical necessity — routine visits beyond required schedules need documented clinical reasons, and 'saw everyone in the building monthly' patterns without individualized documentation attract review.

Common POS 32 Billing Errors

Office E/M codes instead of the nursing facility family
POS 32 during what is actually a skilled Part A stay (misses consolidated billing edits until they find you)
Gang-visit documentation — identical notes across a facility's census on one date is an audit pattern payers know well

POS 32 vs POS 31: The Distinction That Decides Who Bills

POS 31 and POS 32 can describe the same building, the same bed and the same patient — the difference is entirely whether Medicare Part A is paying for the stay on that date of service. That single fact decides whether you may bill Medicare directly or whether the claim belongs to the facility.

	POS 31 — SNF, Part A stay	POS 32 — nursing facility
Payment status	Covered Part A stay in progress	Custodial, or Part A benefit exhausted
Consolidated billing	Applies — most ancillaries belong to the facility	Does not apply
Your professional services	Billable to Part B	Billable to Part B
Therapy, most supplies, technical components	Facility bills them	Billed normally under Part B
Practical effect	Check the exclusion list before billing	Bill as you would for any Part B patient

The trap: assuming a nursing-home resident is permanently one code or the other. A patient admitted under Part A after a qualifying hospital stay is POS 31 — then the benefit runs out, or the stay ends, and the same patient in the same bed becomes POS 32. Practices that set the place of service once at registration and never revisit it generate months of quietly wrong claims in both directions.

Because POS 32 carries no consolidated billing, it is the simpler of the pair operationally: you bill your professional services and the associated ancillaries under Part B as normal, at the facility rate. The discipline required is not in the billing itself — it is in verifying Part A status for each date of service before the claim goes out.

Related POS Codes

POS 31 — SNF Part A POS 12 — Home POS 11 — Office

← 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

Can we bill monthly visits for stable nursing home patients?

Medically necessary visits, yes — and regulations require certain visit schedules that support routine care. What draws audits is frequency without individualized documentation: every resident, every month, identical notes. Document each patient's actual status and management, and appropriate frequency defends itself.

The patient exhausted Part A mid-month. Do we change anything?

Yes — POS flips from 31 to 32 on the status-change date, and consolidated billing stops applying to services after it. Facilities know the exhaust dates; syncing your rounding lists with facility census data monthly prevents the mismatch denials.

What is the difference between POS 31 and POS 32?

Both can describe the same nursing-home bed. POS 31 applies during a covered Medicare Part A stay, where consolidated billing means most ancillary services belong to the facility. POS 32 applies when the resident is custodial or the Part A benefit is exhausted, consolidated billing does not apply, and normal Part B billing resumes.

Can a patient change from POS 32 to POS 31 during the same stay?

Yes, and this is a common source of wrong claims. A resident admitted under Part A after a qualifying hospital stay is POS 31 until that benefit ends or is exhausted, at which point the same patient in the same bed becomes POS 32. Verify Part A status per date of service rather than setting the place of service once at registration.

POS 32: Nursing Facility (Custodial / Non-Part A)