Some clipless cleats allow more adjustability in mounting than others. I use the old Look Delta cleats and they are very adjustable. I toe-out a lot so I also use Kneesavers, a pedal extender which helps keep my heel from hitting the crankarm.
Once riding, the Look cleat allow 9 degrees of rotation, or "float", meaning you can move your heel in and out a bit. Some pedals allow a lot more rotation.
Some people need this movement and some don't, as long as they get the right cleat position to start with.
It took a lot of trial and error to find the set-up that works for me but my knees are happy most of the time.