Is this a Hospital-based facility, or a free-standing? If Hospital-based (which is the POS 22 per your claims), all their claims should be billed on a UB-04, not a CMS-1500, and there is no POS code on those claims.
The POS code on your physician claims communicates where the services were provided, in the doctors' private office (11) where he/she is responsible for all the staff/overhead, etc., or a hospital OP facility (22) where the facility is responsible for paying the ancillary staff, lights/overhead. To report that your provider provided services in POS 11 when in actuality it was a hospital-based facility is fraud.
The problem is with the hospital-based facility. They should be billign for their own services. Even if your physicians are getting the reduced reimbursement since they are not getting paid (nor should they) for the facilities resources, they are getting what they are LEGALLY and ETHICALLY entitled to.
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