Primary Care Coding Alert

Requirements regarding originating and distant sites may now determine payment.

Telehealth is a boon to patients and providers, making healthcare more convenient and accessible. However, billing for telehealth services can be a headache because the rules and requirements can be burdensome to navigate.

Additionally, the rules and requirements have changed significantly during and since the COVID-19 public health emergency (PHE). The Centers for Medicare & Medicaid Services (CMS) has recently issued updated guidance about a return to stricter requirements for billing telehealth services, which goes into effect October 1.

Here’s some information you need to know to bill telehealth services confidently and accurately.

Understand Originating and Distant Site

A basic premise of telehealth is that the patient and the provider are in different locations. So, when you need to figure out the origin site, you need to know which of those locations counts as the origin.

According to the CMS Medicare Learning Network (MLN), the originating site is where the patient is receiving the services. The location of the provider is referred to as the “distant site.”

Prepare for Different Telehealth Requirements

This information pertains to providers who can bill Medicare for their services; check with your patients’ respective payers for their specific guidance on telehealth services.

Right now, the originating site requirements are pretty flexible: “Through September 30, 2025, COVID-19 PHE telehealth flexibilities allow patients to get telehealth wherever they’re located. They don’t need to be at an originating site, and there aren’t any geographic restrictions.”

Starting October 1, however, only patients receiving services regarding behavioral or mental health via telehealth can do so without being subject to originating site requirements and geographic location restrictions. Providers offering telehealth services to patients for other care, including hospice certification services, will have to follow specific guidance on the patient’s originating and provider’s own distant site to bill the services. This is basically a return to telehealth rules before the flexibilities offered during the COVID-19 PHE.

MLN says that starting October 1, statutory limitations for Medicare telehealth services regarding geographic restrictions, location restrictions on where providers can furnish services, and limitations on the scope of practitioners who can provide telehealth services will again go into effect. However, the rules are a little murky because some flexibility extends through the end of calendar year (CY) 2025.

Here’s some of what you need to know, according to MLN:

• “We’ll temporarily suspend telehealth frequency limitations on subsequent inpatient and nursing facility visits (CPT^Ò codes 99231, 99232, 99233, 99307, 99308, 99309, and 99310) and on critical care consultations (HCPCS codes G0508 and G0509) through CY 2025.
• “Teaching physicians may have virtual presence when billing for services provided involving residents in all teaching settings but only in clinical situations when they provide the service virtually (for example, a 3-way telehealth visit with the patient, resident, and teaching physician in separate locations) through December 31, 2025.
• “For all services, we’ve extended the definition of direct supervision that allows the supervising physician or practitioner to provide supervision through a virtual presence using real-time audio-visual interactive telecommunications through December 31, 2025.
• “For a subset of services, we’ve permanently adopted the definition of direct supervision that allows the supervising physician or practitioner to provide supervision through a virtual presence using real-time audio-visual interactive telecommunications.”

Remember These Tips for Billing

Here are some helpful tips from Novitas on information you may need to bill for Medicare telehealth services beginning October 1:

According to a Telehealth FAQ CY 2025 document by CMS: “Physicians and/or practitioners should use [place of service code] POS 02 for Telehealth Provided Other than in Patient’s Home or POS 10 for Telehealth Provided in Patient’s Home (which is a location other than a hospital or other facility where the patient receives care in a private residence).” Such claims would be paid at a non-facility rate.

Keep an eye out for further updates and potential clarifications as CMS evaluates how telehealth services are furnished and how to pay providers for their services.

Rachel Dorrell, MA, MS, CPC-A, CPPM, Production Editor, AAPC