Proper usage of POS codes 31 and 32

Wednesday, March 26, 2025

After the Office of Inspector General discovered Medicare paid millions more for physician services at higher non-facility rates while enrollees were inpatients, CMS is taking steps to ensure proper place of service (POS) code selection.

To prevent overpayments for physician services provided to skilled nursing facility (SNF) and hospital inpatients, CMS recently authorized a system edit to identify instances in which physicians incorrectly use POS code 32.

POS code 31 is used for all services furnished in SNFs for beneficiaries with Part A coverage, according to CMS. POS code 32 is used for all services furnished in nursing facilities (NF), as well as services furnished in SNFs when beneficiaries have exhausted their Part A coverage. For services provided in mixed facilities that include both NF and SNF settings, POS code 31 is used unless the physician can verify that no Part A payment will be made.

CMS’ systems will reject claims with POS 32 that overlap with a previously processed claim for a Part A SNF stay. Revenue integrity professionals can view MLN Matters 13767 for more information.