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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 rendered by hospitals should be billed as telehealth (HCPCS Q3014) or should be billed as though the service was furnished in person (HCPCS G0463 or another appropriate code).

Per Question #3 of subsection LL, where the practitioner is physically located during the service affects whether or not the service should be billed as telehealth.

“If a physician is practicing from a hospital that has registered the patient as a hospital outpatient in the patient’s home, which is serving as a provider-based department of the hospital, we consider the physician and patient to be “in the hospital” and usual hospital outpatient billing rules would apply in terms of billing for the service(s) furnished. In this situation, there is no distant site practitioner and no telehealth service being furnished.”

In other terms, when the patient’s home is made a temporary expansion site of the hospital, the patient is considered to be “in the hospital” when services are provided at the temporary location (their home). If the physician is on-campus of the hospital when the virtual service is rendered then the physician is also considered to be “in the hospital”. When patient and provider are both considered to be “in the hospital” (either physically or conceptually through the temporary expansion waiver) these services cannot be billed as telehealth; modifier 95 should not be reported in conjunction with the professional service and the hospital should not report telehealth originating site facility fee Q3014. Per CMS, these services should be billed as though they were rendered in-person.

However, if the physician is at a location not considered on-campus of the hospital when the service is rendered (e.g. the physician is in their own home, or rendering the service from their private practice address), then the physician is considered to be at a “distant site” from the patient. In these instances, these visits should be billed as a telehealth service; with modifier 95 appended to the professional service and the facility billing Q3014 for the technical component.

COVID-19 Frequently Asked Questions on Medicare Fee-for-Service Billing:
https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf