Wiki Outpatient Clinic Billing

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We are having a friendly debate on which POS to use for an outpatient client that is owned by an Article 28 hospital. I believe it should be 11 and some of the others believe it should be 22. Please help us.
 
I'm not sure how Article 28 impacts this, but from a CMS perspective, if the clinic is operated as a provider-based outpatient department, the place of service should be 22 if it's on campus and 19 if off campus. Place of service 11 would only apply if the clinic is not operated as an outpatient department but as a free-standing independent practice. Another way of saying this is that if the hospital bills a facility charge on a UB for therapeutic services in that clinic, then it is considered an outpatient department and POS 11 would be incorrect.
 
POS 19 for off campus out patient clinic . Is defined by Medicare . Individual payers may or may not recognize this POS with that definition.
 
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