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Can hospitals bill for telehealth services provided by our employed clinicians on the hospital’s UB04 claim form?

Neither the original telehealth expansion waiver announced by CMS on March 17th, or the additional expansions to telehealth outlined by CMS in their COVID-19 Interim Final Rule released on March 30th change the billing options for hospitals as it relates to telehealth services. Hospitals have not been added to the list of CMS approved provider types who may offer telehealth services. Under CMS regulations, telehealth remains a professional service billable on a professional claim form (CMS 1500 claim form or it’s electronic equivalent).

However, hospitals can continue to charge HCPCS code Q3014 for “telehealth originating site fee” if a patient is physically present at your facility while receiving a telehealth service from a provider located at a separate distinct site. *Please note: the reporting requirements for Q3014 were changed by CMS with the release of Interim Final Rule CMS-5531-IFC published on April 30th 2020. For a summary of the updated reporting guidelines for Q3014 please click here*

Hospitals should also be aware that for the duration of the COVID-19 public health emergency CMS is expediting the Medicare enrollment process for physician and non-physician practitioners. Providers who had not enrolled with Medicare previously may choose to do so under the expedited process. Once enrolled, these providers may then re-assign their billing rights to the hospital who could then submit a 1500 claim for the provider’s telehealth service on the provider’s behalf (assuming the practitioner is a CMS approved telehealth provider rendering a CMS approved telehealth service).

For additional information on the expedited Medicare provider enrollment process please see the CMS FAQ document linked below. Our Craneware COVID-19 landing page also contains helpful resources for submitting professional claims for telehealth services.

2019-Novel Coronavirus (COVID-19) Medicare Provider Enrollment Relief Frequently Asked Questions (FAQs)

https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf