# POS: Office vs Outpatient Hospital for E/Ms



## rai2004575 (Jan 31, 2018)

Good afternoon,

I need assistance. I am confused as to how to differentiate which POS is correct to use when billing E/M codes - Office or On/Off Campus - Outpatient Hospital

The physicians are part of a Medical School faculty which is associated with a Hospital. They see patients (E/Ms and office procedures) in an outpatient clinic space owned by the Hospital. It is in the same building as the hospital.

CMS defines the *On Campus - Outpatient Hospital location* as: “A portion of a hospital’s main campus which provides diagnostic, therapeutic (both surgical and nonsurgical), and rehabilitation services to sick or injured persons who do not require hospitalization or institutionalization.  (Description change effective January 1, 2016)”

*Campus* is defined as: "The physical area immediately adjacent to the provider's main buildings, other areas and structures that are not strictly contiguous to the main buildings but are located within 250 yards of the main buildings, and any other areas determined on an individual case basis, by the CMS regional office, to be part of the provider's campus."

*Office* is defined as: "Location, other than a hospital, skilled nursing facility (SNF), military treatment facility, community health center, State or local public health clinic, or intermediate care facility (ICF), where the health professional routinely provides health examinations, diagnosis, and treatment of illness or injury on an ambulatory basis."

Is the fact that the space is owned by the hospital and in the same building indicative that it is therefore "part of the hospital campus", and should be entered with POS "On Campus - Outpatient Hospital"?

Or does this clinic space qualify as a Location, other than a hospital and therefore gets entered with POS "Office" ?

How do I know when "Office" is correct to use or "Outpatient Hospital" is correct to use?


Any insight is greatly appreciated.


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## thomas7331 (Jan 31, 2018)

You'll need to work with your hospital administration on this question because it really depends on how they classify and operate their different spaces within the hospital, i.e. whether or not they choose to make these locations provider based clinics.  If the offices are in the same building as the hospital, this is most likely an on campus provider based clinic and will be a place of service 22, but that is not necessarily the case as there can even be lease arrangements of the space or an independently operated practice which even though within the hospital, could potentially make it a private physician office.  Also, a factor that has to be considered is how the hospital is billing their portion of this.  If the hospital is billing a clinic charge on a UB form for the E&M services, then you'll certainly need to bill a hospital POS on the professional claim, but if the hospital is not charging for the clinic, then an office POS may be appropriate.  The billing requirements can also vary from payer to payer if the contracts dictate it, so that can also affect what place of service needs to be used as well.  It's important to get it correct because it can definitely cause and underpayment or overpayment if you're not using the right POS on the claims.  Sorry not to be able to give a more clear answer - provider based billing is complicated and there isn't an easy answer, but the hospital will need to give you the final word on this.


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