E/M Weekly Tip: "Incident To" Place of Service (POS) 19 or 22

"Incident to" services are limited to the office setting (POS 11). However, if a provider establishes an office in a larger outpatient setting, the "incident to" services and requirements are confined to this discrete part of the facility designated as his or her office. 


  • Hospital-Based Physician (employees of the hospital)
    • The hospital is billing and "incident to" does not apply
    • Bill POS 19 or 22
  • Group of physicians (not employees of the hospital) and the office is confined to the discrete part of the facility
    • The physicians are incurring the expense and "incident to" would apply
    • Bill POS 11 (not POS 19 or 22)

Resource: For more information, please visit the Medicare Claims Processing Manual, 100-02, chapter 15, Section 60.1 at CMS website (PDF, 1.29 MB).

Last Updated: 08/03/2020