# POS 22 vs POS 11



## DebHill1958

If a hospital owns a practice (which may be offsite), employs the physician and staff and incurs all expense for the practice - should this be billed with POS 11 or 22? I was recently "freaked out" to hear that this should be POS 22 which is 180 degree change from what I have always subscribed to. I'm not talking about provider-based billing or hospital based physicians.....just regular physician practices that have been acquired by a hospital?


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## heatherwinters

*Pos*

Check out this article by the AAPC
http://news.aapc.com/index.php/2009/10/pos-codes-do-you-know-where-your-doctor-is/


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## DebHill1958

Thanks for the link but it really doesn't address what I'm looking for. Maybe I'll get some other feedback as well.


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## jmcpolin

I think it would be POS 11 even if it is owned by the hospital it is offsite and in an office.  22 POS to me is when a service is performed in the hospital and the patient is never admitted.


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## mitchellde

If the facility owns the space and employs the staff and all the expenses then it is a 22, the reimbursement then for the provider is less as he is not being reimbursed for the overhead since it is not his overhead.  the facility will then submit a claim for the use of the facility .


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## DebHill1958

Debra,
Do you have any official references to confirm that as this is a 180 degree turn from what I have always been accustomed to and it would send shock waves in the groups I work with. I did something back from AZ Medicare that says the same thing (in a round about way). 

I appreciate your help.


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## mitchellde

There is nothing that I am aware of "in writing" that states this.  It does however come down to ownership among other issues.  The hospital is the owner of the clinic so this is then a facility outpatient clinic not a freestanding physician office.  It is perhaps easier if you look at it as a freestanding outpatient clinic of the facility.  No matter how you say it, the facility is the one paying for everything, the physician is not out the overhead and other expenses.  If you bill as an 11 then the facility cannot submit a claim for the facility's portion.   I do not know of any other way to explain it nor can I point to a single publication that will make it any more clear for you.  
However it is no different than when you have a clinic located within the facility and the physician sees his patient there, if you have no problem seeing this as a POS 22 then use that logic.  Just because the facility chooses to locate an outpatient clinic offsite does not change the fact that it is still an outpatient clinic.
Let me know if this helps in anyway.


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## bran1120

I manage two physician practices that are part of "physician partnerships" with a hospital which basically means that our practice is owned by our hospital.  That does not automatically mean that the hospital is the entity solely responsible for the overhead.  You would need to look at a few things such as how your Tax ID is registered, how your physician contracts read and what the relationship actually is.  You may also need to check your local and state regulations.  

In our case our POS for services performed in our office is 11, not 22.  Even though our practice is hospital-owned, our physician organization has a different and separate Tax ID than the hospital itself does.  POS 22 is only used for services in which the patient is actually being seen within a hospital department such as radiology, outpatient surgery, lab, etc.  Do some research and contact the person responsible for credentialing your physicians and/or your group and you should be able to find a definite answer for your practice.


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## mitchellde

Yes you are correct but a physician partnership is totally different from hospital owned clinic.  The poster stated that the clinic was owned by the facility and the staff were employees, i take it then that the facility pays for everything.  But you are correct if the physician pays rent and reimburses the facility for staff out of their reimbursement.  they facility has to have some form of compensation for services rendered in their facility, it canot be an arrangement where they provide this free of charge in exchange for the patient  to have other services with in the facility as that comes close to a kickback which brings up other issues.   So in your practice then somehow the facility is receiving compensation and your staff is paid out of the physician revenues not the facilities.


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## LLovett

*Split billing*

http://www.fdcpa.com/Healthcare/Split-Billing-Overview-Presentation.pdf

I found this on a quick google search, it is a nice explanation of split billing. Which I agree with Debra, it sounds like what you should be doing if the hospital is incurring all the cost.

Laura, CPC, CPMA, CEME


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