The term “originating site” is defined by Medicare as the place where the healthcare visit begins. In the case of telemedicine, this would usually be the place where the patient is. When a patient sees a doctor virtually, the location of the patient is the originating site.

Why are Originating Sites Important?

Originating sites are important because they determine if providers will be paid for services. Caring doctors who have chosen their profession to treat and heal patients still need to earn their living too. A telehealth service will only be covered by Medicare if it is from a recognized originating site. Doctors and other healthcare providers must be sure their patient is using an approved originating site to seek care. Medicare will not reimburse providers for services not “covered”.

What Kind of Sites are Approved as Originating Sites by Medicare?

Medicare approved originating sites are located in one of two kinds of places on a map. They must be located in either a county outside of the boundaries of a metropolitan statistical area (MSA) or within a rural Health Professional Shortage Area (HPSA). A county outside an MSA is considered rural. Patients there may need to travel great distances to find healthcare. HPSAs are also often found to be in rural locations. If too few doctors have settled in those areas they may be reliant on telehealth to meet the needs of the community. With only a few exceptions originating sites must be located within one of these two kinds of locations. They must also be an approved healthcare facility. Places like hospitals, doctor’s offices, skilled nursing facilities, and community mental health centers to name a few are okay. Places like the corner store, a local library, or a private home are not.

Exceptions to Originating Site Restrictions

The rules and regulations for Medicare change regularly and there are some exceptions to the originating site rules. Some providers do qualify as originating sites no matter their location. These are providers who were participating in a Federal telemedicine demonstration project as of December 31, 2000. In addition, the SUPPORT act allows a private home to be used as an

originating site. This act supports the treatment of a substance abuse disorder or a related mental health issue. In 2018 expanded coverage using telehealth in the case of stroke or potential stroke was also added.

How has COVID-19 Changed Originating Site Rules?

In March of 2020 the 1135 waiver eased many restrictions in an effort to make telehealth more accessible. As the importance of reducing the spread of the virus became a priority this waiver was enacted. It worked to make important health care available to Americans in a way that was safe and easy. It allowed for telehealth services to be provided from anywhere in the country. It also made a patient’s home an approved site to receive care. This waiver is a temporary emergency measure. It remains to be seen if it will impact the rules will be concerning originating sites in the future.