The Centers for Medicare & Medicaid Services (CMS) released a toolkit on Medicare payments to providers of telehealth and telemedicine services on Friday, March 20.  The toolkits give further information beyond the original guidance on telehealth issued as part of the first emergency supplemental aid package.

FQHCs and FQHC-LAs can only serve as originating sites (the site where the patient is located during the telehealth service).  They are not permitted to bill Medicare as distant sites (where the physician is located during the service).  CMS issued FAQs which confirmed that the Secretary’s waiver authority does not extend to the scope of services that certain health centers may provide as distant site providers (see FAQ #4 on page 6).  The recent waiver only modifies the definition of an originating site to allow for the patient to receive telehealth services in any location, including the patient’s home.  The types of providers that can bill as distant sites was not modified.  Even though the FAQ addresses rural health clinics, the same logic would apply to FQHCs and FQHC-LAs.  A third stimulus package, currently stalled in the Senate, would allow FQHCs and FQHC-LAs to bill as distant site providers.