Obtaining Medicare reimbursements for telehealth services isn’t always easy — especially considering CMS telehealth originating site rule restrictions. While telehealth coverage is on the rise, a recent Harris Poll study shows practice adoption has not kept up with patient demand for convenience and better population health care for chronic conditions.
CMS recently has agreed to pay for more telehealth services, made billing easier, and increased physician payment rates, but telehealth originating site rules still leave many scratching their heads.
Here’s how to decipher the originating site geographical restrictions. Think, ‘Telehealth Originating Site = Patient Location’ The originating site is where the beneficiary (patient) is physically located during the visit. Count These Locations as Qualifying Telehealth Originating Sites For services to be covered by Medicare, the patient must visit an originating site that is located in:
- A county outside of a Metropolitan Statistical Area (MSA)
- A rural Health Professional Shortage Area (HPSA) in a rural census tract
Say ‘Yes’ to These Establishments as Allowed Telehealth Originating Sites
To further complicate matters, only certain establishments qualify as telehealth originating sites. Medicare will reimburse for telehealth services only when a beneficiary visits an originating site authorized by CMS. CMS authorized telehealth originating sites include:
- Physician or practitioner office
- Hospital or Critical Access Hospital (CAH)
- Rural Health Clinic
- Federally qualified health center (FQHC)
- Hospital-based or CAH-based renal dialysis center (including satellite locations)
- Skilled Nursing Facility (SNF) or Community Mental Health Centers (CMHC)
- Renal Dialysis Facility and the homes of beneficiaries with End-Stage Renal Disease (ESRD) on home dialysis
- Mobile Stroke Unit
Exclude These Places from Acceptable Telehealth Originating Sites Sites that do not currently qualify as CMS authorized telehealth originating sites include:
- A patient’s home—except in the case of a substance use disorder or a co-occurring mental health disorder
- A patient’s workplace
- An independent renal dialysis facility
Hint: Don’t guess when it comes to reimbursements; use this tool to locate Medicare eligible telehealth originating sites!
Check for Allowed Telehealth Originating Site Providers
Medicare also has stipulations on who can provide telehealth services. Eligible telehealth originating site providers include:
- Nurse Practitioners (NPs)
- Physician Assistants (PAs)
- Nurse Midwifes (CNMs)
- Clinical Nurse Specialists (CNSs)
- Certified Registered Nurse Anesthetists (CRNAs)
- Clinical Psychologists (CPs) who bill independently
- Clinical Social Workers (CSWs)
- Registered Dietitians (RDs)
- Nutritional Professionals
Prevent Telehealth Denials, Underpayments with 4 Details There are so many details you must consider when billing Medicare for telehealth services. But getting your reimbursement doesn’t have to be a hassle. Here are some ways you can avoid denials and get reimbursed for your telehealth claims:
- Understand eligibility. Make sure that your patient is covered for teleheath services before the appointment and know that your practice is eligible to bill for telehealth services. This way you will avoid unexpected denials and unhappy patients who have to foot the bill.
- Include complete information on claims. Include both a telehealth originating site and a distant site on your claims. There are a select few instances when you don’t need both, but in most cases you do.
- Communicate live. Medicare only covers patient telehealth services that are performed via real-time video conferencing with both audio and video communications.
- Don’t forget the facility fee. The facility fee is paid to the originating site for hosting the patient during the telemedicine visit. To receive the facility fee, bill HCPCS code Q3014. Medicare provides more details about this code in this booklet.
Pin Down Answers to Common Originating Site Compliance Traps
If you feel like you’ve only scratched the surface on telehealth originating site billing, you’re not alone. Following the documentation and supervision requirements is confusing. Unanswered FAQs that can leave you out of compliance include:
- Are there requirements for what staff must be present at the originating site with the patient?
- If a physician works from home is this an acceptable distant site if the originating site meets all requirements?
- If a PCP is present at the originating site and will be following up on a care plan, and a (sub)specialty physician is providing a consultation at a distant site, can both providers bill for the visit?
- Can you bill an originating and distant site under the same tax ID number?
- When don’t you need to include both a distant and originating site on a claim?
Key: You must know the answers to these questions to pull in your full reimbursements. To help you improve your telemedicine reimbursement, coding and billing expert, Stephanie Thomas, CPC, CANPC, gives you an easy to understand breakdown of both telehealth originating site and distant site regulations.
In her 45-minute telehealth online training, Stephanie shows you exactly how to apply these rules in real-world situations to improve your compliance and pay up.
Commonly Purchased Online Trainings and Resources