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We have decided to make a patient’s home a temporary expansion site of our provider-based department. Our provider-based department services are always split-billed; the hospital submits a claim for the technical portion of the service and the physician submits their own claim for the professional portion of the service. When services are rendered virtually, does the rendering physician’s physical location during the service affect whether these visits should be billed as telehealth?

Yes. Within the latest update of their “COVID-19 Frequently Asked Questions on Medicare Fee-for-Service Billing” document, CMS added a new subsection entitled “LL. Hospital Billing for Remote Services”. The new subsection aims to further clarify when remote services...