How to bill Medicare for telehealth services

Q: Telehealth services are listed in the proposals for Medicare changes in 2014. What are these services, and as a practitioner, am I eligible to bill for them?

A: The Medicare, Medicaid and Benefits Improvement and Protection Act of 2000 provided for an expansion of Medicare payment for telehealth services. Coverage and payment include consultations, office visits, individual psychotherapy, and pharmacologic management, which must all be delivered via a telecommunications system and substitute for an in-person encounter.

Later, the list of telehealth services was expanded to include subsequent hospital care services, subsequent nursing facility care services,  individual psychotherapy, pharmacologic management, psychiatric diagnostic interview examination, and many others. The eligible geographic areas include rural health professional shortage areas (HPSA) and counties not classified as a metropolitan statistical area.

For Medicare payment to occur, interactive audio and video telecommunications must be used, permitting real-time communication between the distant site practitioner and the Medicare beneficiary. The patient must be present and participating in the telehealth visit.

Medical practitioners who can bill for a covered telehealth service vary by state law, but they may include:

• physician,

• nurse practitioner,

• physician assistant,

• nurse midwife,

• clinical nurse specialist,

• clinical psychologist,

• clinical social worker, and

• registered dietician or nutrition professional

The service provided must be within a practitioner’s scope of practice under state law.

An originating site is the location of an eligible Medicare beneficiary at the time the telehealth service occurs. These may include a hospital, the practitioner’s office, a critical access hospital (CAH), a rural health clinic, a federally qualified health center, a hospital-based or critical access hospital-based renal dialysis center, a skilled nursing facility, or a community mental health center. 

A distant site is where the practitioner is located at the time the telehealth service is provided. Payment for the telehealth service is equal to the current physician fee schedule amount for the service. 

For 2014, the Centers for Medicare and Medicaid Services is proposing to modify the regulations describing eligible telehealth originating sites to include HPSAs located in rural census tracts of urban areas, as determined by the Office of Rural Health Policy. This change will more appropriately identify sites within urban HPSAs that have rural characteristics and improve access to telehealth services in shortage areas.

Benefits to remote areas of using telehealth may include:

• transmission of medical images for diagnosis and advice on disease prevention,

• health advice in emergency cases, and

• patient care and promotion of good health via patient monitoring and follow-up.

The nonclinical uses of telehealth technologies include: distance education, such as grand rounds and patient education; research; patient remote admission; and online information and health data management. Telehealth services afford doctors and hospitals the ability to share resources, and they provide incentives for reducing the number of readmitted patients.