Medicare Telehealth versus Telemedicine

We have received many questions that have indicated confusion between telehealth and telemedicine, and which rules apply to which services within these two benefit categories. While there is a perceived relation between these types of services they are distinctly different.

Telemedicine refers to a group of services that may be provided to a patient without any physical patient contact. Services may be provided via a telephone (audio) connection, or via some type of online communication such as a patient/provider portal or via email interactions between the patient and practitioner. Typically, most telemedicine services are noncovered by Medicare. However, CMS has opened some of the codes for coverage during the COVID-19 public health emergency (PHE).

Telehealth refers to a distinct level of established services that have traditionally been performed via a face-to-face interaction between the patient and practitioner. This group of services has been grouped together in a distinct policy that allows this limited amount of traditional face-to-face services to be performed via an audio and video connection as a replacement to the in person, face-to-face interaction. Telehealth allows the interaction to still occur face-to-face; however, it can be achieved via the audio and video connection.

This benefit was set apart as a specific addition to Medicare policy in SSA 1834(m). The criteria requires real time communication between the patient and practitioner (audio and video), the patient geographic location is in a rural or non-metropolitan statistical area (based on ZIP Code eligibility), and patient consent is required. 

The site where the patient is located is considered the originating site and may bill Q3014 to cover the cost of a professional to set up the audio and video communication system and assist with the service provided, if required. The site where the practitioner is rendering the telehealth service is known as the distant site. The practitioner will bill for the service s/he provides based on the list of approved telehealth services. All telehealth services in the benefit are professional services.

CMS issued the MLN Telehealth Booklet which explains the coverage criteria, provides a listing of eligible originating sites, and eligible distant site practitioners that may perform services via telehealth. The booklet also contains a listing of applicable procedure codes that are allowed to be performed via telehealth and information on the appropriate geographic location of the patient that is allowed for telehealth services. During the PHE, the list of services allowed to be performed via telehealth have been temporarily expanded. The MLN Telehealth Booklet includes the complete list of codes, with those that are temporarily identified as such.

Posted 4/21/2020