A report released this month (April 2021) by the US Department of Health and Human Services Office of Inspector General of recently audited Medicare payments for telehealth services finds that CMS paid practitioners for some telehealth claims associated with services that did not meet certain Medicare requirements around originating-site eligibility and asynchronous technology.

Aside from the report's findings, it also offers a useful summary of Medicare's originating-site eligibility requirements and conditions of payment for telehealth services.

Eligible originating sites are: 

• in a county outside of a metropolitan statistical area (MSA) 

• in a health professional shortage area (HPSA) that is either outside of an MSA or within a rural census tract, or 

• an entity participating in a federal telemedicine demonstration project that has been approved by (or receives funding from) the Secretary of Health and Human Services.

In addition, the originating site must be one of the following: practitioner office, hospital, critical access hospital (CAH), rural health clinic, federally qualified health center, hospital-based or CAH-based renal dialysis center, skilled nursing facility, or community mental health center.

Medicare generally pays for telehealth services only when an interactive audio and video telecommunications system is used, permitting real-time communication between the beneficiary at the originating site and the practitioner at the distant site. Under certain circumstances, Medicare will pay for telehealth services when furnished through an asynchronous “store and forward” system. Unlike an interactive audio and video telecommunications system, asynchronous store and forward technology is the non-interactive transmission of medical information, such as the transmission of digital MRI or CT images which are reviewed and interpreted a later time by a radiologist at the distant site. Additionally in Alaska and Hawaii only, Medicare will also pay for telehealth services using asynchronous store and forward technology when the originating site is part of a federal telemedicine demonstration project.

It should be noted that CMS expanded coverage for telehealth services beyond that described above for the duration of the COVID-19 public health emergency.