Out of State Providers
Doctors of Medicine and Osteopathy – The requirement that a doctor of medicine be legally authorized to practice medicine and surgery by the State in which he/she performs his/her services means a physician is licensed to practice medicine and surgery.
A doctor of osteopathy who is legally authorized to practice medicine and surgery by the State in which he/she performs his/her services qualifies as a physician. In addition, a licensed osteopath or osteopathic practitioner qualifies as a physician to the extent that he/she performs services within the scope of his/her practice as defined by State law.
(Similar regulations exist for other types of practitioners, see manual).
Distant site providers may continue to use through 2025 their currently enrolled practice location address instead of their home address as the location of where they are providing services via telehealth.
Items and services furnished outside the United States are excluded from coverage (with exceptions for beneficiaries traveling in Canada and emergency situations).
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Payment may not be made for a medical service (or a portion of it) that was subcontracted to another provider or supplier located outside the United States. For example, if a radiologist who practices in India analyzes imaging tests that were performed on a beneficiary in the United States, Medicare would not pay the radiologist or the U.S. facility that performed the imaging test for any of the services that were performed by the radiologist in India.
As a condition of Medicare Part B payment for telehealth services, the physician or practitioner at the distant site must be licensed to provide the service under state law. When the physician or practitioner at the distant site is licensed under state law to provide a covered telehealth service (i.e., professional consultation, office and other outpatient visits, individual psychotherapy, and pharmacologic management) then he or she may bill for and receive payment for this service when delivered via a telecommunications system.
The contractor shall approve covered telehealth services if the physician or practitioner is licensed under State law to provide the service. Contractors must familiarize themselves with licensure provisions of States for which they process claims and disallow telehealth services furnished by physicians or practitioners who are not authorized to furnish the applicable telehealth service under State law. For example, if a nurse practitioner is not licensed to provide individual psychotherapy under State law, he or she would not be permitted to receive payment for individual psychotherapy under Medicare. The contractor shall install edits to ensure that only properly licensed physicians and practitioners are paid for covered telehealth services.
MFTs and MHCs
How do I enroll to perform telehealth services to patients located in my home state or another state?
Practitioners who perform telehealth services should enroll based on their enrollment scenario. Refer to the scenarios below as a guide for completing the paper application. For faster and easier enrollment, providers are encouraged to submit their applications electronically through PECOS.
Practitioner Only Renders Services in a Private Practice: The practitioner renders telehealth services from his/her home in Florida. The practitioner completes all applicable sections of the paper CMS-855I. In section 4B of the CMS-855I, enter the location where the telehealth service is performed (e.g., office, home). Select the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only.” This option prevents the practitioner’s home address from being published on Care Compare, a tool for Medicare beneficiaries to find and compare different Medicare providers.
The practitioner submits the completed application to First Coast Services Options, the MAC that processes enrollment applications for Florida.
Practitioner reassigns all benefits to a group. Practitioner and group are in the same state: The practitioner reassigns benefits to a group In Maryland but will be rendering telehealth services from his/her home in Maryland. The practitioner completes all applicable sections of the CMS-855I. In section 4F of the CMS-855I, the practitioner lists the group accepting the new reassignment of benefits from the practitioner. If the group is already enrolled, no further action is needed. If the group is not enrolled, they will complete all applicable sections of the CMS-855B and list their office locations in section 4A. The practitioner does not list his/her home address on the CMS-855I or on the group’s CMS-855B application. Physicians/practitioners who bill for Medicare telehealth services should report place of service (POS) code 02 or 10 beginning January 1, 2024.
The practitioner and group submit the CMS-855I and CMS-855B to Novitas Solutions, the MAC that processes enrollment applications for Maryland.
Practitioner reassigns all benefits to a group. Practitioner and Group are in different states: The practitioner reassigns benefits to a group in Maryland but will be rendering telehealth services from his/her home in Florida. The practitioner must enroll in the state where the group is located because they are submitting claims on behalf of the practitioner. The practitioner completes all applicable sections of the CMS-855I. In section 4F of the CMS-855I, the practitioner lists the group accepting the new reassignment of benefits from the practitioner. If the group is already enrolled, no further action is needed. If the group is not enrolled, they will complete all applicable sections of the CMS-855B and list their office locations in section 4A. The practitioner does not list his/her home address on the CMS-855I or on the group’s CMS-855B application. The practitioner can continue to bill as if he/she furnished the service in person, through December 31, 2024.
The practitioner and group submit the CMS-855I and CMS-855B to Novitas Solutions, the MAC that processes enrollment applications for Maryland.
Inter-Jurisdictional Reassignments
If a reassignor is reassigning their benefits to a reassignee located in another contractor jurisdiction (a permissible practice), the principles in this section 10.3.1.4(E) apply unless another CMS directive states otherwise.
- The reassignor must be properly licensed or otherwise authorized to perform services in the state in which he/she has his/her practice location. The practice location can be an office or even the individual’s home (for example, a physician interprets test results in his home for an independent diagnostic testing facility).
- The reassignor need not – pursuant to the reassignment – enroll in the reassignee’s contractor jurisdiction nor be licensed/authorized to practice in the reassignee’s state. If the reassignor will be performing services within the reassignee’s state, the reassignor must enroll with the contractor for (and be licensed/authorized to practice in) that state.
- The reassignee must enroll in the contractor jurisdictions in which (1) it has its own practice location(s), and (2) the reassignor has his or her practice location(s). In Case (2), the reassignee:
- Shall identify the reassignor’s practice location as a practice location on its Form CMS-855B or Form CMS-855I.
- Shall select the practice location type as “Other health care facility” and specify “Telemedicine location” in the Practice Location Information of its Form CMS-855.
- Need not be licensed/authorized to perform services in the reassignor’s state.
To illustrate, suppose Dr. Smith is in Contractor Jurisdiction X and is reassigning his benefits to Jones Medical Group in Contractor Jurisdiction Y. Jones must enroll with X and with Y. Jones need not be licensed/authorized to perform services in Dr. Smith’s state. However, in the Practice Location Information section of the Form CMS- 855B it submits to X, Jones must list Dr. Smith’s location as its practice location.
Teleradiology
Interpretation Provided Outside of the United States: Generally, Medicare will not pay for health care or supplies that are performed outside the United States (U.S.). The term “outside the U.S.” means anywhere other than the 50 states of the U.S., the District of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands. See Pub. 100-02, chapter 16, section 60, for exceptions to the “outside the U.S.” exclusions.
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