POS 31 is the Place of Service code for a Skilled Nursing Facility. It’s a two-digit code you report on professional claims, including the CMS-1500, to show that care was delivered to a patient during a covered Medicare Part A stay.
Place of service 31 applies when the patient has an active Part A benefit on the date of service. When Part A isn’t active, POS 32 applies instead. The building doesn’t decide it.
Two things changed. Medicare turned on a system edit for these claims on July 1, 2025, and the CY 2026 practice expense methodology now splits payment between POS 31 and POS 32.
POS 31 in medical billing turns on five things: Part A status, the POS 32 comparison, denial codes, consolidated billing, and the 2026 rate change.
What Is POS 31 in Medical Billing?
A Place of Service code tells the payer where care happened. That single field decides which fee schedule applies to the claim, so it moves money. POS 31 in medical billing marks the skilled nursing facility setting on the physician side of the claim.
The Official CMS Definition of Place of Service 31
The CMS Place of Service Code Set defines code 31 as a facility that primarily provides inpatient skilled nursing care and related services to patients who need medical, nursing, or rehabilitative services, but that doesn’t provide the level of care available in a hospital.
In plain terms, an SNF sits between the hospital and home. CMS last modified its place of service page on February 9, 2026.
One qualifier matters more than the definition itself. The CMS description tells you what kind of building qualifies. Medicare’s rule for picking the code is the patient’s Part A coverage status on the date of service, and those aren’t the same test.
Where POS 31 Goes on the Claim: Box 24B and Loop 2400
| Claim format | Field | What goes there |
|---|---|---|
| CMS-1500 (paper) | Item 24B | POS code, per service line |
| 837P (electronic) | Loop 2400, SV105 | POS code, per service line |
| CMS-1500 | Item 32 | Service facility name, address, and ZIP when care is furnished outside the home or physician office |
POS is a required field. Leave it blank or key an invalid value and the claim comes back unprocessable before anyone looks at the coding.
One trap catches teams that bill across settings. For services paid under the Medicare Physician Fee Schedule, only one POS may be submitted on a CMS-1500. So when a patient’s setting changes inside a billing period, you split the claim. Our CMS-1500 box-by-box guide walks through each field.
When Should You Use POS 31?
The POS for skilled nursing facility claims is 31 when the patient has an active Medicare Part A benefit on the date of service, per CMS MLN Matters MM13767. Two supporting conditions sit behind that: the facility holds Medicare certification, and the patient is inside the 100-day benefit window.
The Three Conditions That Must All Be True
- Patient has an active Medicare Part A SNF benefit on the date of service
- Facility holds current Medicare certification as a skilled nursing facility
- Service is a physician or qualified NPP professional service billed to Part B
All three have to hold. Miss one and the claim belongs under a different code, which is where most skilled nursing facility POS errors start.
What Your Documentation Has to Support
| Documentation | Why it matters |
|---|---|
| Qualifying 3-day inpatient hospital stay, with admission and discharge dates | Establishes Part A SNF eligibility |
| SNF admission within 30 days of hospital discharge | Required for the benefit to attach |
| Physician certification of skilled need | Supports medical necessity |
| Daily nursing notes showing skilled services | Survives post-payment review |
| Verified Part A days remaining on the date of service | Determines POS 31 versus POS 32 |
One detail trips up POS 31 medical billing more than the rest. Observation time and emergency department time don’t count toward the 3-day qualifying stay. A patient can sit in the hospital four days and still fail the test.
When Not to Use POS 31
Most POS 31 in medical billing errors aren’t knowledge gaps. A billing team picks the code by habit, because the patient lives in an SNF, instead of checking what Medicare is paying for that day.
Four Situations Where POS 31 Is the Wrong Code
- Patient has exhausted the 100-day Part A benefit, use POS 32
- Patient is a long-term custodial resident who never had a Part A stay, use POS 32
- Patient is in an assisted living facility, use POS 13
- Visit was delivered by telehealth, use POS 02 or POS 10
That last one surprises people. Telehealth codes describe how care reached the patient, not where the patient sleeps. Our guide to POS 10 home telehealth claims covers the home-based version.
The Assumption That Costs the Most Money
During a covered Part A stay, plenty of services a practice would otherwise bill belong to the facility under SNF consolidated billing. Physician professional services are carved out and stay separately billable. Most ancillary and technical services aren’t.
Send those to Medicare and you get a denial. Working that denial wastes the cycle, because the claim wasn’t yours to submit. The consolidated billing section below sorts out which is which.
POS 31 vs POS 32: What Is the Difference?
One question settles it. Does the patient have an active Medicare Part A SNF benefit on this date of service? Yes means POS 31. No means POS 32.
The One Question That Decides the Code
The deciding factor isn’t the building, the care type, or how skilled the service looks on paper. It is coverage status on the encounter date.
Plenty of published guides frame the POS 31 and 32 difference as skilled care versus custodial care. That framework produces the exact error CMS now flags, because a patient on day 104 can be getting real skilled therapy and still belong under POS 32.
POS 31 and POS 32 Compared Side by Side
| Factor | POS 31 (Skilled Nursing Facility) | POS 32 (Nursing Facility) |
|---|---|---|
| Patient stay type | Active Medicare Part A skilled stay | Long-term custodial, or SNF after Part A exhausted |
| Qualifying hospital stay | 3-day inpatient stay required | Not required |
| CMS payment classification | Facility setting | Non-facility setting |
| Practice expense treatment | Reduced facility PE | Full non-facility PE |
| Relative payment | Lower | Higher |
| E/M codes used | 99304 to 99316 | 99304 to 99316 |
| Coverage source | Medicare Part A per diem, physician bills Part B | Medicare Part B, Medicaid, or private pay |
| Benefit cap | 100 days per benefit period | None |
Both columns use the same E/M family. In POS 31 in medical billing, and under the 32 place of service too, code selection follows medical decision making or time. Our SNF CPT code guide breaks down each level.
Why POS 32 Pays More Than POS 31
Under POS 31 the facility already collects a Part A per diem covering overhead, so CMS pays the physician’s professional claim at the lower facility rate. Under POS 32 no separate facility fee goes to Part B, and the physician collects the higher non-facility rate.
That inversion carries a compliance edge. Because place of service 32 pays more, using it during an active Part A stay looks like upcoding to an auditor, whether anyone intended it or not.
POS 31 or POS 32? A Two-Question Decision Check
Two questions settle almost every SNF claim. Most billing teams answer the first and skip the second, which is why denials keep landing on services that weren’t billable to begin with.
Question One: Is the Part A Benefit Active Today?
Confirming the POS for skilled nursing facility rounds starts with the facility. Ask for the stay status and reconcile the census with each facility you serve every month. Verify per date of service, not per patient, because status flips mid-stay and nobody calls to tell you.
Question Two: Is This Service Yours to Bill?
Check whether the service survives SNF consolidated billing. Physician professional services are carved out. Most ancillary and technical services belong to the facility during a covered stay.
The Decision Matrix
| Service type | Part A active | Part A not active |
|---|---|---|
| Physician professional service (E/M, procedure, professional interpretation) | Bill Part B with POS 31 | Bill Part B with POS 32 |
| Ancillary or technical service (therapy, most supplies, technical component of lab and imaging) | Bill the SNF, not Medicare | Bill Part B with POS 32, therapy still bundled |
The top-left cell is where POS 31 medical billing lives. The bottom-left cell is where practices lose revenue they never invoice. A short list of high-cost services stays separately billable even during a covered stay, and 31 POS in medical billing depends on knowing which list applies.
What Happens to POS 31 When Part A Runs Out at Day 100?
Same patient. Same room. Same physical therapy on the same schedule. On day 101 POS 31 in medical billing gives way to POS 32, because the benefit ended and nothing about the care did.
The Same Bed, a Different Code
Medicare caps the Part A benefit at 100 days per benefit period. Once it’s gone, or once skilled need ends, place of service 31 stops being correct and place of service 32 applies going forward.
The failure isn’t the rule itself. It’s not knowing which day it happened. Most practices find out weeks later, on a remittance, after a month of claims went out under the wrong 31 place of service.
Fix it upstream. Run a monthly census reconciliation with each facility and flag Part A days remaining per patient.
Transfer Days and the Split-Claim Problem
A patient discharges from the hospital and admits to the SNF the same afternoon. The POS follows where the face-to-face encounter happened. A morning hospital round is POS 21 inpatient hospital rules, even though that patient sleeps in the SNF that night.
CMS anticipated this. The CR 13767 edit carries twelve conditions where it does not fire, and two of them cover claims whose date equals the SNF admission date or the discharge date. Clean transfer-day billing was built into the design.
Which POS Do You Use in a Mixed SNF and Nursing Facility?
One building. One hallway. Two residents in adjacent rooms. One is in a covered Part A stay, the other exhausted Part A eight months ago. Same nurse, same physician round, two different POS codes.
CMS settles this. For services furnished in facilities that include both nursing facility and skilled nursing facility settings, known as mixed facilities, POS 31 is used unless the physician can verify that no Part A payment will be made for the service.
That reverses what most guides say. Published guidance treats it as neutral per-patient verification. CMS sets a default with a burden of proof. POS 31 is the presumption, and the skilled nursing facility POS only changes when your team proves the exception.
Verify per date of service, not per patient and not per building. A resident who was POS 32 last month can be POS 31 this month after a hospitalization and readmission, and nobody’s going to call you about it.
| Verifying Part A status before every encounter is the whole game here, and it’s a front-end job, not a billing job. If your team is finding out on the remittance, our Part A eligibility verification team can build that checkpoint into your workflow. |
Is POS 31 a Facility or Non-Facility Code?
POS 31 is a facility setting under Medicare’s payment structure. POS 32 is non-facility. That classification, not the service you performed, moves the payment.
What Facility Status Does to Your Payment
Every CPT code carries three RVU components: physician work, practice expense, and malpractice. In a facility setting CMS assumes the facility absorbs overhead such as exam rooms, supplies, and clinical staff time, so it reduces the practice expense share.
Work RVUs don’t move between settings. Practice expense does. That split has held for years across inpatient vs outpatient coding, and it changed on January 1, 2026.
The CY 2026 Practice Expense Change
CMS finalized a policy that reduces the portion of facility practice expense RVUs allocated based on work RVUs to half the amount allocated to non-facility services for the same code.
Nursing facility E/M codes used to carry identical facility and non-facility practice expense values. Since January 1, 2026, they don’t. The same visit pays two different amounts now, depending on whether POS 31 or POS 32 sits in Box 24B.
Sizing that gap takes care. Published figures measure different things: one code against its 2025 rate, the spread between the two POS codes, or the blended effect on a practice billing both. Pull the current fee schedule files for the codes you bill.
What CMS Has Proposed for CY 2027
CMS published the CY 2027 PFS Proposed Rule on July 16, 2026. Under its practice expense and site of service provisions, CMS proposes to eliminate the differential and realign payment for nursing facility visit codes 99304 to 99316 across both settings.
That would reverse the CY 2026 change. It’s a proposal, not a final rule, and the comment period closes September 14, 2026.
For a billing team the takeaway holds either way. POS accuracy is a compliance requirement regardless of which direction rates move, and a workflow built around a rate gap that might not survive the final rule is one you’ll rebuild in January.
| If you’ve been billing SNF visits through 2026 without checking which practice expense rate applied, a medical billing audit will tell you what the methodology change cost you. |
Why Medicare Started Rejecting POS 32 Claims in 2025
For years, POS 31 in medical billing errors went undetected because Medicare had no system edit that could catch them. That changed on July 1, 2025.
The OIG Audit That Triggered It
A May 2023 HHS OIG audit A-04-21-04084 reviewed calendar years 2019 and 2020 and found about 2.1 million physician service claim lines at risk from incorrect place of service reporting.
Medicare had paid about $44.6 million in overpayments across the review, split between skilled nursing facility claims and hospital inpatient claims. OIG pointed at the cause: CMS had no Common Working File edits that could detect the pattern.
What CR 13767 Does
CMS answered with Change Request 13767, issued through CMS Transmittal R13073CP on March 13, 2025. It told the Common Working File to build a system edit and an Informational Unsolicited Response. Effective July 1, 2025. Implementation July 7, 2025.
In practice, Medicare now compares your professional claims against posted Part A SNF stays and flags the mismatches. Two mechanisms, not one. Going forward, matching claims get rejected. Looking backward, claims that already paid get adjusted.
Which Claims the Edit Catches
The edit covers dates of service January 1, 2025 and after. It fires when a professional claim reported with POS 32 overlaps a previously posted covered Part A SNF claim on bill types 21X and 18X swing bed, and it excludes critical access hospital swing bed.
CMS also built twelve conditions into the edit where it won’t fire, including the transfer-day cases covered above.
What Denial Code Do You Get for a Wrong POS on an SNF Claim?
Two different failures produce two different denials, and billing teams mix them up every week. Telling them apart changes how you work the claim, so it’s worth two minutes.
CARC 58: The POS Overlap Rejection
CMS specifies CARC 58 for this scenario: treatment was deemed by the payer to have been rendered in an inappropriate or invalid place of service. Group Code CO. The transmittal names it twice, once for claims returned unprocessable at submission and once for claims adjusted after payment.
So when CARC 58 lands with Group Code CO on an SNF claim, Medicare is telling you POS 32 went out while a covered Part A stay sat on file. The correction is POS 31. Our claim denial management services team works these at the claim line.
CARC 16 and RARC M77: Missing or Invalid POS
A missing or invalid POS field sends the claim back unprocessable with CARC 16 and RARC M77. Different cause, different fix.
CARC 16 means the field is blank or wrong. CARC 58 means the field is populated, valid, and contradicts the patient’s coverage status. Work a CARC 58 like a CO-16 denial code and you burn a cycle for nothing. That’s the invalid POS denial code distinction most teams miss.
The Message Your Patient Receives
When the adjustment processes, the patient gets MSN 13.10: Medicare Part B doesn’t pay for items or services provided by this type of healthcare provider, since records show the patient was receiving Medicare Part A benefits in a skilled nursing facility on that date.
CMS publishes a Spanish translation alongside it. Your patient help desk is going to field calls about this notice, and knowing the exact wording lets staff close them on the first call.
Can You Rebill a Claim That Was Recouped for the Wrong POS?
The takeback already happened. In 32 POS in medical billing, that is the usual shape of it: money came back out of a deposit weeks after the claim paid clean, and now somebody wants to know whether it’s recoverable or whether you’re stuck.
What Medicare Does to Claims It Already Paid
Alongside the rejection edit, CMS built an Informational Unsolicited Response. It finds professional claims you already collected on with POS 32 whose dates of service fall within or overlap an incoming covered Part A SNF claim.
Same date-of-service scope: January 1, 2025 and after. When the IUR fires, the contractor adjusts the claim instead of leaving it paid.
Who Corrects the POS, and What Happens Next
Contractors correct the POS themselves on claim lines where POS 32 should have been POS 31. They override edit 268H where appropriate, and they’ll test that adjustments process at the correct POS 31 payment rate.
So this isn’t a denial you appeal from scratch. Medicare recodes the line and reprices it. The gap between the non-facility rate you collected and the facility rate you should have collected turns into an overpayment.
Working the Recoupment
Contractors follow normal recoupment procedures for claims adjusted into an overpayment. Normal procedures carry normal rights: the standard overpayment notice, the standard rebuttal window, and the standard appeal path if the Part A stay data is wrong.
Two caveats, stated straight. Commercial payers handle POS corrections their own way, and there’s no single answer across contracts. And when the Part A overlap is accurate, the adjustment is correct, which makes workflow repair the right move, not an appeal.
Aged POS 32 claims sitting past 90 days are harder to reconcile than fresh ones, which is where our recover recouped SNF claims workflow starts.
| Recoupments on POS 31 claims arrive in batches, months after the fact, and they hide inside a deposit. If takebacks are showing up in your AR and nobody is working them, that’s a fixable problem. |
What Can You Bill Separately During a Part A SNF Stay?
POS 31 in medical billing does something no other place of service code does. It doesn’t only set a payment rate. It flags a bundle, and that bundle decides who gets to send the claim.
How Consolidated Billing Works
The Balanced Budget Act of 1997 created CMS SNF Consolidated Billing. During a covered Part A stay, Medicare pays the facility a bundled per diem meant to cover most of what the resident receives, and the SNF submits one consolidated bill. A short list of services stays outside the bundle.
The facility side of that bill runs on SNF revenue codes and the UB-04, which is a separate claim from yours.
Who Bills What: The Split That Costs Practices Money
| Service during a covered Part A stay | Who bills it |
|---|---|
| Physician and qualified NPP professional services | You, direct to Part B with POS 31 |
| Professional interpretation of a diagnostic test | You, the professional component |
| Physical, occupational, and speech therapy | The SNF |
| Most routine drugs, supplies, and equipment | The SNF |
| Technical component of most lab and imaging | The SNF |
| Specifically excluded high-cost services | You, per the current CMS exclusion list |
CMS names the excluded categories: physician services, dialysis-related services, ambulance transport at the start or end of the stay, chemotherapy and its administration, certain customized prosthetics, and radioisotope services. Those lists change, so look them up. Don’t memorize them.
The Professional and Technical Component Trap
Physician services sit outside consolidated billing. A service carrying both a professional and technical component splits, though. Your read is yours. The technical component isn’t.
Practices that bill globally on SNF patients collect partial denials and write them off, when the right move was invoicing the SNF for the technical side.
One more rule most guides skip: therapy services stay subject to consolidated billing even outside covered Part A stays. Teams that assume the bundle disappears when Part A ends get caught on CPT 97530 therapeutic activities and the rest of the therapy set.
Which CPT Codes Are Billed With POS 31?
The same code family applies under POS 31 and POS 32. The POS changes what you get paid, not which code you pick. Code selection follows medical decision making or total time on the date of the encounter.
The Nursing Facility E/M Code Set
| Code range | What it reports | Notes |
|---|---|---|
| 99304 to 99306 | Initial nursing facility care | Once per admission, per physician, per specialty. Principal physician appends modifier AI |
| 99307 to 99310 | Subsequent nursing facility care, per day | One E/M per patient per day from the same physician |
| 99315 to 99316 | Nursing facility discharge day management | 99315 for 30 minutes or less, 99316 for more |
CPT 99318 was deleted effective January 1, 2023. Annual assessments now report with the subsequent care codes. Any template, superbill, or charge capture library still carrying 99318 needs updating, and our nursing facility E/M code selection guide covers the MDM thresholds for each level.
Codes That Trigger a POS Mismatch
Nursing facility codes depend on place of service. Bill 99304 through 99316 with POS 11 for an office visit and the claim mismatches, because those codes don’t belong in an office. The reverse fails too: office and outpatient codes submitted with POS 31 won’t survive adjudication.
One exception catches even careful teams. Under CMS guidance, when a physician sees an SNF inpatient inside the physician’s own office during a Part A stay, inpatient status still governs and POS 31 remains the correct minimum code. That answers a question 31 POS in medical billing raises every week.
What POS Do You Use for a Telehealth Visit to an SNF Patient?
A telehealth visit to a patient in a skilled nursing facility isn’t billed with POS 31. Telehealth uses POS 02 or POS 10, depending on where the patient sits during the call.
The logic runs backward from what most teams expect. POS 31 and POS 32 identify the facility where the service would have happened in person. Telehealth POS codes identify the delivery method. Use POS 02 when the patient is somewhere other than home, which is what an SNF is. Use POS 10 when the patient is in their own residence.
Then the modifier layer. Append modifier 95 telehealth rules for synchronous audio-video encounters, and modifier 93 for audio-only where the payer accepts it. The payment rate follows the POS code, not the modifier, and that’s the part most billing teams get backward.
Effective January 1, 2026, CMS removed frequency limits on telehealth subsequent nursing facility visits. Medical necessity governs how often you follow up by video now, not a visit count. Commercial telehealth policies vary by contract and by state, so Medicare rules aren’t a safe default for every plan.
POS 31 vs POS 11, 21, 22, 12, and 13
POS 31 in medical billing sits inside a cluster of codes that look interchangeable on a claim form and behave nothing alike. Most POS errors are neighbor errors, not random ones.
| POS | Setting | Use it when | Rate type |
|---|---|---|---|
| 11 | Office | Independently owned physician office | Non-facility |
| 12 | Home | In-person care in the patient’s private residence | Non-facility |
| 13 | Assisted Living Facility | Resident of an assisted living facility, not a private home | Non-facility |
| 21 | Inpatient Hospital | Formal admission order, patient is a hospital inpatient | Facility |
| 22 | On Campus Outpatient Hospital | Hospital-owned outpatient department on the main campus | Facility |
| 31 | Skilled Nursing Facility | Active Medicare Part A SNF stay | Facility |
Three neighbor errors show up most. POS 11 gets used for an SNF round because the physician’s office is the billing address. POS 21 stays on the claim after the patient moves to the SNF. And POS 12 home visit claims get billed for assisted living residents, which is POS 13.
Each one costs a claim. For the hospital outpatient comparison, see our POS 22 outpatient hospital rules guide.
POS 31 Examples: Six Real Billing Scenarios
Rules land faster with a patient attached. Six POS 31 in medical billing scenarios, each drawn from a pattern that shows up in SNF billing every month.
Scenario 1. An internist makes a subsequent visit on day 5 of a covered SNF stay, following a 4-day hospital admission for a hip fracture. Part A is active, the facility is certified, and the service is a professional E/M. POS 31, subsequent nursing facility care.
Scenario 2. Same patient, day 103. Part A ran out three days ago and the family pays out of pocket now. The physician still rounds weekly. POS 32 applies, and the practice needed to catch that date before the claims went out.
Scenario 3. A wound care specialist rounds on four residents in one hallway. Two sit in covered Part A stays, two are long-term custodial. Four claims, two different POS codes, verified per patient per date of service.
Scenario 4. An outside physical therapy group bills Medicare for treating a resident on day 12 of a covered stay. Denial follows. That claim belonged to the SNF under consolidated billing, and the fix is invoicing the facility rather than appealing.
Scenario 5. A cardiologist runs a synchronous video follow-up with a resident inside a Part A stay. POS 02 with modifier 95, not POS 31, because the POS follows the delivery method.
Scenario 6. A patient discharges from the hospital and admits to the SNF the same afternoon. The hospitalist saw that patient at 9 a.m. POS 21 for the morning encounter, because the code follows where the face-to-face contact happened.
POS 31 vs Modifier 31, and How to Catch Errors Before Submission
POS 31 and Modifier 31 Are Not Related
POS 31 is a place of service code reported in Item 24B that identifies where care happened. Modifier 31 is a CPT modifier with no connection to the care setting.
They share a number and nothing else. Same story for POS 32 and modifier 32. Practices lose real time chasing the wrong one, and payer calls go sideways when a biller asks about the wrong code type.
Ten Checks Before an SNF Claim Goes Out
Run these before submission. Most of them also catch the clearinghouse rejection codes that never reach the payer.
| # | Check |
|---|---|
| 1 | Part A status verified for this specific date of service |
| 2 | Qualifying 3-day inpatient hospital stay documented |
| 3 | SNF admission within 30 days of hospital discharge |
| 4 | Facility holds current Medicare certification |
| 5 | Skilled need documented in orders and nursing notes |
| 6 | CPT selected from 99304 to 99316, not office codes |
| 7 | Modifier AI appended if this is the principal physician’s initial visit |
| 8 | Service confirmed as excluded from consolidated billing |
| 9 | POS entered in Item 24B, one POS per claim |
| 10 | Rendering provider enrolled and privileged at this facility |
Item 1 is the one that pays for itself, and eligibility checks before each visit are where it belongs. Item 10 catches a quieter problem: practices bill SNF rounds under a group NPI that lacks facility privileges, which produces a provider credentialing services denial before POS ever becomes the issue.
How One O Seven RCM Manages POS 31 Claims for Providers
Everything above is a workflow problem before it becomes a billing problem. Practices that get POS 31 right built a verification checkpoint. They didn’t hire better coders.
Front-end verification comes first. We confirm Part A status per date of service and reconcile the census monthly against each facility a practice serves. That’s what prevents CARC 58 instead of working it after the fact.
Denial and recoupment recovery runs behind it. CARC 58 rejections get worked at the claim line, IUR adjustments get reconciled against remittances, and takebacks get tracked so they don’t vanish inside a deposit. Our denial recovery for SNF claims team owns that queue.
Consolidated billing review closes the gap. We split what belongs to the SNF from what stays separately billable, so technical components get invoiced to the facility rather than written off. POS 32 medical billing gets the same treatment on the other side of the benefit, and POS 31 in medical billing sits on this one.
| If your SNF claims are coming back with CARC 58, or takebacks are landing months after the fact, we’ll run a free look at your POS 31 and POS 32 claim history and tell you what’s recoverable. |
This guide reflects CMS guidance current as of the publication date. Verify all codes, modifiers, and effective dates against current CMS sources before claim submission.
POS 31 in Medical Billing: Frequently Asked Questions
What does POS 31 mean in medical billing?
In POS 31 in medical billing, the code marks a Skilled Nursing Facility. You report this two-digit code in Item 24B of the CMS-1500 when a physician or NPP treats a patient during a covered Medicare Part A SNF stay. It tells the payer the service happened in a facility setting, and that sets the payment rate.
The code appears on the physician side only. The SNF bills Medicare separately on the UB-04 for the Part A per diem.
Is POS 31 a facility or non-facility code?
POS 31 is a facility code. Medicare pays professional claims submitted with place of service 31 at the facility rate, which is the lower of the two tiers, since the SNF already collects a Part A per diem covering overhead. POS 32 is classified non-facility and pays the higher rate.
The CY 2026 practice expense methodology widened that gap for nursing facility E/M codes.
What is the difference between POS 31 and POS 32?
Medicare Part A coverage status on the date of service decides it, and that single test governs POS 31 in medical billing. Use POS 31 when the patient has an active Part A SNF benefit. Use POS 32 when the patient is in a nursing facility, has exhausted the 100-day benefit, or never qualified for Part A.
That’s the POS 31 and 32 difference in one line: coverage, not care type.
Does POS 32 pay more than POS 31?
Yes. In POS 32 in medical billing, the code is non-facility and pays the higher practice expense rate, while POS 31 is a facility code and pays the lower one. Most billing teams assume the opposite, since POS 31 sounds like the heavier setting.
That inversion is why POS 32 during an active Part A stay reads as upcoding to an auditor.
What happens to the POS code when Part A runs out at day 100?
The POS changes to 32 even though nothing else about the visit does. Once the 100-day Part A benefit exhausts or skilled need ends, place of service 31 stops being correct, and claims from that date forward use POS 32. Same patient, same room, same care, different code.
Run a monthly census reconciliation with each facility so you catch the date before the claims go out.
Which POS code do you use in a building with both SNF and long-term residents?
CMS calls these mixed facilities and sets POS 31 as the default. You use POS 31 unless the physician can verify that no Part A payment will be made for that service. The burden sits on proving the exception. You aren’t choosing between two equal options.
Verify per date of service rather than per patient, since a resident’s status can flip after a hospitalization and readmission.
Why was my POS 32 claim rejected?
A 32 place of service claim overlapping a posted covered Part A SNF stay gets rejected under the CMS edit effective July 1, 2025. The remittance carries CARC 58 with Group Code CO, meaning the payer treats the place of service as inappropriate or invalid. Resubmit with POS 31.
CARC 16 paired with RARC M77 is a different invalid POS denial code. That one means the field was blank or malformed. It wasn’t contradicted.
Can I bill therapy with POS 31?
Not during a covered Part A stay, no. Under the skilled nursing facility POS, physical, occupational, and speech therapy fall under SNF consolidated billing, so the facility bills them and outside providers invoice the SNF instead of Medicare. Submitting therapy to Part B with POS 31 produces a denial.
Therapy also stays subject to consolidated billing outside covered Part A stays, which catches teams expecting the bundle to end at day 100.
What POS code do you use for telehealth to a nursing home patient?
Use POS 02 when the patient is in the nursing facility during the visit, and POS 10 when the patient is at home. Telehealth POS codes describe the delivery method, while POS 31 and POS 32 describe the physical setting where in-person care would have happened.
Append modifier 95 for synchronous audio-video. The payment rate follows the POS code, not the modifier.
Is POS 31 the same as modifier 31?
No. In POS 31 in medical billing the two share a number and nothing else. POS 31 is a place of service code entered in Item 24B that identifies where care was delivered. Modifier 31 is a CPT modifier appended to a procedure code and has no connection to the care setting.
The same holds for POS 32 and modifier 32. Confirm which code type a payer is asking about before you pull the claim.
