The COVID-19 pandemic has been ongoing for nearly two years already. With businesses choosing between going fully remote or bankrupt, healthcare providers opt in to perform more telemedicine services than ever. Surprisingly, hospitals are taking the lead. In 2022, treatment cooperation between so-called “originating” hospitals providing in-person care and “distant site” telemedicine hospitals is quite widespread. It is regulated by Chapter 45 and article 28 of the Consolidated Laws of New York, entitled “Credentialing and privileging of health care practitioners providing telemedicine services”. Enacted in 2014, this legislation is as relevant as ever in 2022. It specifies the fact that an inpatient hospital is allowed to provide telemedicine services to patients who are physically located and receiving treatment in a different inpatient hospital.
An assignment of responsibilities: who treats and who bills
According to the article, a “distant site” facility is a Medicare-participating hospital licensed in any state, that has coined a written agreement with another hospital (an “originating” facility) to make available one or more of its health care practitioners to such hospital to provide telemedicine services to patients treated at that originating hospital. On contrary, an originating hospital" is the place where a patient is located during the telemedicine sessions. It may rely on the credentialing and privileging decisions made by the distant site hospital in granting or renewing privileges to a health care practitioner working at the distant-site hospital, if:
(a) the distant site hospital participates in Medicare and local Medicaid;
(b) each involved physician is licensed to practice in this state;
(c) the distant site hospital evaluates all credentialing information concerning each health care practitioner providing telemedicine services, performs all required verification activities, and acts on behalf of the originating site hospital for such credentialing purposes;
(d) the distant site hospital regularly reviews complaints or other circumstances, the credentials, privileges, physical and mental capacity, and competence in delivering health care services of each health care practitioner providing telemedicine services and reports the finding results to the originating hospital, notifying it of any significant inconsistencies, such as a loss of privileges.
To sum up: if you are an institutional healthcare provider, you may enter into an agreement with another hospital and allow your patients to receive telemedicine treatment furnished by a physician from that hospital. At the same time, you may delegate some of your physicians to the virtual treatment of patients who are physically located in a different hospital.
Distant site telemedicine services are billed in a similar way to “normal” telehealth visits. Namely, such services must be billed with the modifier 95. However, the CPT code Q3014, which describes telehealth originating site facility fee, must be appended on such claims.
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