Teleradiology enrollment scenarios

Section 1834(m) of the Social Security Act specifies the circumstances under which Medicare makes payment for services that are ordinarily furnished in person but are instead furnished via two-way telecommunications technology. CMS’ longstanding interpretation is that services that are not ordinarily furnished in person, such as care management, remote monitoring, and remote interpretation of diagnostic tests, are not included in the statutory definition of Medicare telehealth services.

Teleradiology refers to the electronic transfer of radiological images, such as X-rays, CT scans, and MRIs, from one site to a radiologist situated at a remote location for interpretation and reporting. Since these services are not typically provided in person, they do not qualify for telehealth flexibility. A teleradiologist must be enrolled in the state corresponding to the location where they are physically present while performing the service. If the teleradiologist is working from their home, that address must be listed as the practice location. A physical office cannot be substituted if it is not where the interpretation and reporting occur.

Provider has a private practice - no reassignments exist:

• Dr. Smith interprets tests from his home in MD
• Dr. Smith submits an 855I to the MD MAC and lists his home address on the application
• Dr. Smith selects the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” to prevent his home address from being published on Care Compare
• Claims will be paid based on Dr. Smith’s home location

Provider reassigns to a group in the same state:

• Dr. Smith interprets tests from his home in MD for Jones Medical Group, which is also in MD.
• Dr. Smith submits an 855I to the MD MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
• Jones submits an 855B to the MD MAC listing Dr. Smith’s home address as a practice location
• Jones selects the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” to prevent his home address from being published on Care Compare
• Claims will be paid based on Dr. Smith’s home location

Provider reassigns to a group out of state

• Dr. Smith interprets tests from his home in MD for Jones Medical Group, which is in FL.
• Dr. Smith submits an 855I to the MD MAC to reassign to Jones Medical (no location listed, all locations on the 855B)
• Jones submits an 855B to the MD MAC listing Dr. Smith’s home address as a practice location
• Jones selects the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only” to prevent his home address from being published on Care Compare
• Claims will be paid based on Dr. Smith’s home location
• Note: This scenario is consistent with section 10.3.1.4(E) (Inter-Jurisdictional Reassignments) of the Program Integrity Manual (PIM), chapter 10

As a reminder, providers reporting home addresses as practice locations should select the practice location type as "Business Office for Administrative/Telehealth Use Only" or "Home Office for Administrative/Telehealth Use Only" in PECOS or the CMS-855. This keeps their home address from being published on Care Compare. Providers can contact QPP@cms.hhs.gov if a home address needs to be suppressed from the website.

Read the following article for information on telehealth enrollment scenarios.