Q&A: Originating site fee for telehealth during the COVID-19 PHE

Q: Some of our physicians who ordinarily provide services in our provider-based department (PBD) are now providing services to patients in our relocated PBDs, including patients' home. Are we allowed to bill an originating site fee in these circumstances?

A: In an Interim Final Rule with Comment Period published April 30, CMS clarified for payment for hospital outpatient department (HOPD) services is an originating site fee when physicians who ordinarily practice in a PBD furnish telehealth to patients located in one of the hospital’s “relocated” PBDs, including the patient’s home. An originating site fee may be billed by the hospital when:

• A physician who ordinarily practices in a HOPD furnishes a telehealth service
• The patient is registered as a hospital outpatient
• The patient’s location is considered a PBD, including a “relocated” PBD such as their home

Telehealth services traditionally originate from a facility location where the patient is located, and the physician is located at a distant site. The facility bills an originating site fee for the administrative, clinical, and clerical support at the originating site, and the physician or other professional bills an appropriate E/M or other approved telehealth code. For situations where the patient comes to a PBD to receive telehealth from a distant site physician, these normal rules still apply. Under this clarification, the originating site where the patient is located may be the patient’s home (if it is designated as a PBD of the hospital) and the hospital is being paid to cover the administrative and clerical support when one of their department’s physicians is calling out to the patient in their home.

Editor's note: Information in this Q&A originally appeared in "Identify newly reimbursable outpatient services during the COVID-19 pandemic," by Kimberly A. Hoy, JD, CPC