Nursing Facility Versus Skilled Nursing Facility Place of Service

National Government Services has received an increased number of calls regarding claim denials for billing with the incorrect POS code. This issue primarily involves confusion between skilled nursing facilities and nursing facilities.

POS 31 is indicated as a “facility which primarily provides inpatient skilled nursing care and related services to patients who require medical, nursing or rehabilitative services but does not provide the level of care or treatment available in a hospital.”

POS 32 is indicated as a “facility which primarily provides to residents skilled nursing care and related services for the rehabilitation of injured, disabled, or sick persons, or, on a regular basis, health-related care services above the level of custodial care to other than individuals with intellectual disabilities.”

• If the patient requires a greater level of care and is receiving inpatient type services, then POS 31 would be appropriate.
• POS 32 is used when the patient doesn’t qualify for the Medicare Part A skilled nursing coverage. They still require health related services, but they are just a step above custodial care and are not meeting a skilled stay.

It’s important to know the status of the patient and provide the correct POS on the Medicare Part B claim that is filed. If the patient is in Part A covered skilled nursing stay, then POS 32 would not be appropriate. If the patient has left that skilled stay, then POS 31 would no longer be appropriate.

Also, keep in mind that if you see patients in your office but they are in a skilled facility stay, you should be billing POS 31 for the services you render according to the special considerations CMS indicated in the POS policy for registered inpatients.

You may find more information on this and place of service guidelines in the CMS Internet-Only Manual, Medicare Claims Processing Manual, Chapter 26, Section 10.5.

Posted 8/13/2025