National telehealth policy sets many restrictions on patient location, services provided over telemedicine and facilities at which patients receive these services. Those are discussed below. However, the Medicare Chronic Care Management Program is a national policy that set no such restrictions on practicing telemedicine. The program was adopted in order to help practitioners better provide monthly care to patients with two or more chronic conditions through telehealth services. Patients can be located anywhere, even in the middle of a metropolitan city, and they may receive services from any facility, including their home or office. Visit our informational page to learn more about the Medicare CCM Program and telemedicine.
Medicare limits the type of healthcare professionals who are eligible to provide telemedicine services to Medicare patients. Any provider not on the list below may not legally provide telehealth services.
There are four forms of telemedicine applications, commonly referred to as telehealth modalities. With the exception of the Medicare CCM Program which has it’s own modality restrictions, Medicare restricts reimbursement based on the type of technology used by the physician to deliver care.
Live, two-way video interactions between patient and provider, also referred to as “real-time” video, is the gold standard of care. With the exception of a few pilot programs in Alaska and Hawaii, Medicare will only reimburse for telehealth services delivered over videoconferencing.
With the exception of the Medicare CCM Program, Medicare does not reimburse for services delivered through store-and-forward methods, e.g. email or fax.
Remote patient monitoring
Currently, Medicare does not having any specific legislation regarding reimbursement for RPM. It is likely that this will change in the near future — using monitoring devices in combination with videoconferencing or telephone calls is an ideal way to do remote physical examinations of patients on a regular basis.
Medicare does not reimburse for the use of mobile communication devices to deliver care to patients.
With the exception of the Medicare Chronic Care Management Program, Medicare places certain restrictions on where patients can be located when receiving telehealth services. Because Medicare sees telehealth as a tool that should specifically target people in remote, rural areas, it has limited the geographic location of patients receiving remote care. Patients must be either:
To check if an originating site is eligible to receive telemedicine services, an originating site search tool has been created by the Center for Connected Health Policy.
Medicare not only limits the site location where patients may receive telehealth services, it also limits the type of facility where patients may receive these services. For example, even if a patient is in an HPSA, they may not receive care from their home or office, as those are not eligible facilities. The eligible facilities where a patient may receive telemedicine-delivered services are:
Again, this is only a facility-requirement for the patient’s location. The physician may be located in a facility outside of this list. Furthermore, patients being seen through the Medicare CCM Program may be located anywhere.
Currently, the Centers for Medicare & Medicaid Services decide to approve a submitted Current Procedural Terminology (CPT) code based on the type of service that was provided over telehealth. They have certain services for which they do reimburse (see category 1 below) and certain services for which they do not reimburse (see category 2 below).
The services provided are similar to existing services, such as professional consultations, office visits, and office psychiatry services, that are approved for telemedicine delivery. When Medicare is deciding whether to approve new codes, they largely consider similarities between the requested service and existing telehealth services.
If services are not similar to Medicare-approved telehealth services, reimbursement is not granted. When reviewing requirements, Medicare assesses whether the service delivered by telemedicine is accurately described by the corresponding CPT code, even when delivered via remotely, and whether the use of telemedicine technology to deliver the service demonstrates clinical benefit to the patient.
Here is a list of Medicare-approved telehealth services, last updated February 2018.
In order to appropriately bill for synchronous telehealth services, practitioners should submit the appropriate Healthcare Common Procedure Coding System (HCPCS) or CPT code along with the telemedicine Place of Service code 02. The Place of Service 02 indicates the location in which the services took place.
If located in Hawaii or Alaska, practitioners should use the appropriate CPT or HCPCS code for the professional service in addition to the GQ modifier. The GQ indicates that the service was provided “via an asynchronous telecommunications system.”
The federal Health Resources and Services Administration (HRSA) defines telehealth as:
“The use of electronic information and telecommunications technologies to support long-distance clinical health care, patient and professional health-related education, public health and health administration.”
Telemedicine is often used when referring to traditional clinical diagnosis and monitoring that is delivered by technology. Some consider it a subset of telehealth, but the two are used interchangeably.
Store-and-forward refers to the electronic transmission of medical information, such as digital images, documents, and pre-recorded videos through secure email transmission. This mode of telehealth delivery is common in dermatology, radiology, pathology and ophthalmology.
Medicare defines an originating site as “the location of an eligible Medicare beneficiary at the time the service furnished via a telecommunications system occurs.”
Medicare uses the term “distant site” when referring to the site at which the practitioner who is providing telemedicine care is located. Oftentimes, Medicare reimburses distant sites who furnish telemedicine services.
Remote patient monitoring (RPM) uses technical equipment to collect medical and other health data from patients. It is then delivered electronically to a practitioner at a distant site for review.
Mobile health involves transmitting patient health information using smartphones or tablets. It typically requires downloading some for of software.
This term refers to state legislation that allows physicians to provide telemedicine services to patients in a state they are not fully licensed. This does not apply to Medicare legislation.