POS - Senior center

A physician wants to render services at a senior complex. The patients live in their
own apartments. The center wants to give him a room to use (no cost) to see patients. I contacted our local Medicare carrier and asked what Place of Service I would use. She states that because the physician is not paying overhead the services cannot be billed
as office visits, Place Of Service 11.
She said that they have documentation from CMS stating that when services are rendered in
A Senior Center, the physician can bill his services at Place Of Service 33 (Custodial Care Facility),
and they can use the CPT® codes associated for services at that POS (99324-99337).
I asked for a copy of the document and she said it was an internal document and it could not be
shared.
Does this make sense to you?