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Website for Determining if Location Qualifies as a Medicare Telehealth Originating Site

on Thursday, 6 September 2018 in Health Law Alert: Erin E. Busch, Editor

Have you wondered how to determine whether your location is eligible for a Medicare telehealth originating site payment? If you have, the Health Resources & Services Administration (“HRSA”), which is a federal agency, has an easy, accessible method for doing just this. You simply bring up the web site and enter your location (i.e., street address, city, state, and zip code), and an answer pops up on the screen in a few moments. Click here to visit the web site.

As background, Medicare pays for a limited number of Part B services (e.g., office or other outpatient visits) furnished by a distant site physician or practitioner (e.g., nurse practitioner, physician assistant, clinical nurse specialist, clinical psychologist, or clinical social worker) to an eligible Medicare beneficiary via a telecommunications system. Except for Hawaii and Alaska, an interactive audio and video telecommunications system that permits real-time communication must be used.

The originating site is the location of the Medicare patient at the time the telehealth service is furnished. The permissible originating sites include: the offices of physicians or practitioners; hospitals; critical access hospitals; rural health clinics; federally qualified health centers; skilled nursing facilities; and community mental health centers. An originating site must be in a county outside of a Metropolitan Statistical Area (MSA) or a rural Health Professional Shortage Area (HPSA) located in a rural census tract. The originating site is paid an originating site facility fee for the telehealth service provided. The fee is updated annually by CMS, and for calendar year 2018, the fee is 80 percent of the actual charge or $25.76, whichever is less.

We encourage you to bookmark the above web site as a handy tool to check to see if your site qualifies geographically for payment as an originating site for purpose of the Medicare telehealth rules. Each calendar year, the geographic eligibility of an originating site is established based on the status of the area as of December 31st of the prior calendar year. The eligibility then continues for the full calendar year. For that reason, you should re-check each year on or after January 1.

Joseph P. Loudon

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