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In Medicare and commercial telehealth reimbursement, every synchronous audio-video or audio-only clinical encounter connects two distinct physical locations defined by Section 1834(m) of the Social Security Act (42 U.S.C. § 1395m(m)) and 42 CFR § 410.78: the originating site (where the patient is physically located) and the distant site (where the billing physician or non-physician practitioner is located). Accurately distinguishing originating site vs. distant site telehealth determines whether a facility can bill the HCPCS Q3014 originating site facility fee, whether the distant-site clinician must report Place of Service (POS) 02 vs. POS 10 alongside CPT Modifier 95 or 93, and which state licensure and telemedicine credentialing by proxy rules govern the encounter.
What Is an Originating Site in Telehealth vs. a Distant Site?
Under the Medicare Claims Processing Manual, Chapter 12, Section 190, CMS separates the clinical, geographic, and billing responsibilities of the two endpoints of a telehealth platform encounter:
- Originating Site (Spoke / Patient Location): The physical location of an eligible Medicare beneficiary at the time the service is furnished via a telecommunications system. Under statutory 42 U.S.C. § 1395m(m)(4)(C)(ii), traditional facility/clinical originating sites include: the offices of physicians or practitioners; hospitals; Critical Access Hospitals (CAHs); Rural Health Clinics (RHCs); Federally Qualified Health Centers (FQHCs); hospital-based or CAH-based Renal Dialysis Centers (including satellites); Skilled Nursing Facilities (SNFs); Community Mental Health Centers (CMHCs); mobile stroke units; and—under specific statutory expansions and public health waivers—the beneficiary’s home (for mental health, substance use disorder treatment, monthly ESRD-related clinical assessments, and acute stroke evaluation).
- Distant Site (Hub / Practitioner Location): The physical site at which the physician or authorized non-physician practitioner delivering the professional service is located at the time the service is provided via a telecommunications system. Statutory distant-site practitioners under 42 CFR § 410.78(b)(2) include physicians, nurse practitioners (NPs), physician assistants (PAs), nurse-midwives, clinical nurse specialists (CNSs), certified registered nurse anesthetists (CRNAs), clinical psychologists, clinical social workers, registered dietitians or nutrition professionals, marriage and family therapists (MFTs), and mental health counselors (MHCs).
| Dimension | Originating Site (Patient Location) | Distant Site (Practitioner Location) |
|---|---|---|
| Who Is Physically Present? | The patient (and optionally a telepresenter nurse/MA at a clinical site) | The billing physician or QHP delivering the clinical evaluation |
| Primary Medicare Claim Billed | HCPCS Q3014 (Originating site facility fee, if patient is in an eligible clinical facility) | CPT / HCPCS Professional Code (e.g., 99202–99215, G0425–G0427) with POS 02 or 10 |
| Can a Patient’s Home Bill? | No — When the patient is at home (POS 10), no entity may bill Q3014 |
Yes — Distant practitioner bills professional fee with POS 10 |
| State Medical Licensure Rule | Governs jurisdiction: the practitioner must generally hold a license in the originating site’s state | Practitioner’s physical location must be reported in Item 32 of CMS-1500 per MAC guidance |
| Hospital Credentialing Rule | Originating hospital may privilege distant specialists via 42 CFR § 482.12(a)(8)–(9) Credentialing by Proxy | Distant-site hospital or telemedicine group maintains primary Joint Commission/CMS credentialing file |
Place of Service (POS) 02 vs. POS 10: Telehealth Place of Service Codes Compared
To distinguish telehealth encounters where the patient is in their private residence from encounters where the patient is hosted inside a clinic or hospital originating site, CMS split the national Place of Service code set into two dedicated telehealth codes reported on Item 24B of the professional CMS-1500 (837P) claim:
| POS Code | Official CMS Descriptor | Where Is the Patient Located? | MPFS Reimbursement Rate Formula | Is HCPCS Q3014 Billable by a Facility? |
|---|---|---|---|---|
| POS 02 | Telehealth Provided Other than in Patient’s Home | Hospital, clinic, physician office, SNF, RHC, FQHC, or CMHC originating site | Paid at the lower MPFS Facility Rate (because practice expense overhead is borne by the originating facility) | Yes — The eligible clinical originating site may separately bill HCPCS Q3014 |
| POS 10 | Telehealth Provided in Patient’s Home | Patient’s private residence (or temporary lodging/shelter functioning as home) | Paid at the higher MPFS Non-Facility (Office) Rate under CMS MPFS rules | No — No facility overheads exist at the patient’s residence; Q3014 is prohibited |
In addition to selecting POS 02 or POS 10, distant-site practitioners append Modifier 95 for synchronous audio-video telehealth or Modifier 93 (or FQ) for qualified synchronous audio-only interactions, while legacy institutional claims use Modifiers GT and G0 (such as G0 for acute stroke telestroke identification and treatment).
HCPCS Q3014: Originating Site Facility Fee Rules
When a Medicare beneficiary travels to an eligible clinical originating site (such as a rural primary care clinic, Critical Access Hospital, or Skilled Nursing Facility) to use its exam room, broadband connection, digital diagnostic peripherals (electronic stethoscope, otoscope, retinal camera), and clinical telepresenter staff to connect with a remote specialist, that physical facility incurs overhead costs:
- Billing HCPCS Q3014: The clinical originating site submits HCPCS Code Q3014 (Telehealth originating site facility fee) to its Medicare Administrative Contractor. Payment is a flat, inflation-indexed statutory fee under Social Security Act § 1834(m)(2)(B) (approximately $30 per encounter under the annual Medicare Economic Index update), subject to the Medicare Part B deductible and 20% coinsurance.
- Hospital Outpatient & CAH Revenue Codes: Institutional originating sites billing on Form CMS-1450 (UB-04) report
Q3014under Revenue Code 0780 (Telemedicine — General Classification). - Same-Day In-Person Visit Restriction: If the originating site’s own physician also performs a medically necessary, separately identifiable in-person E/M service on the same calendar day, both the in-person E/M and
Q3014may be billed only when clinical documentation supports distinct services; however, if the patient is an inpatient of a hospital, routine room-and-board DRG bundling rules apply.
How Is Originating Site Telehealth Used in Clinical Research and Decentralized Clinical Trials?
In clinical research and decentralized clinical trials (DCTs), the hub-and-spoke originating site architecture solves three major trial operations and regulatory challenges:
- Hub-and-Spoke Trial Recruitment and Remote Investigator Oversight: Under FDA’s Conducting Clinical Trials With Decentralized Elements guidance, a Principal Investigator (PI) at a tertiary academic medical center (the distant site) can conduct protocol-mandated safety evaluations, informed consent discussions, and neurological/oncological assessments while the trial participant visits a community clinic, local imaging center, or retail health hub acting as the originating site.
- State Medical Licensure Compliance Across Trial Sites: Because state medical practice acts define the “location of the practice of medicine” as the physical location of the patient (the originating site), trial sponsors and telehealth networks must verify that any distant-site investigator or sub-investigator holds an active medical license (or Interstate Medical Licensure Compact privilege / state clinical trial licensure exception) in the state where the participant is physically located at the moment of the televisit.
- Routine Clinical Trial Cost Attribution (NCD 310.1): When a clinical trial protocol incorporates standard-of-care telehealth consultations billed to Medicare under the Medicare Clinical Trial Policy, the trial’s billing compliance team must route professional claims from the distant site (`POS 02` or `POS 10`) separately from any facility `Q3014` claim generated by a spoke clinic originating site.
Frequently Asked Questions
If a physician conducts a telehealth visit from their own home while the patient is also at home, which Place of Service code applies?
POS 10 applies. Place of Service codes 02 and 10 are determined strictly by where the patient (originating site) is located during the encounter, not where the distant-site clinician is sitting. Because the patient is in their home, the distant practitioner reports POS 10.
Can a distant-site physician bill HCPCS Q3014?
No. Q3014 reimburses only the physical facility hosting the patient at an eligible clinical originating site. The distant-site practitioner bills only the professional CPT/HCPCS evaluation and management or consultation code.
What are the permanent statutory exceptions to Medicare’s rural geographic originating site rule?
Even outside temporary congressional extensions of broad telehealth flexibilities, Section 1834(m) of the Social Security Act permanently waives rural geographic and facility restrictions (allowing the patient’s home in any rural or urban area to serve as an eligible originating site) for: (1) diagnosis, evaluation, or treatment of a mental health disorder (subject to periodic in-person visit rules unless an exception applies), (2) treatment of a substance use disorder (SUD) or co-occurring mental health disorder, (3) monthly home dialysis ESRD clinical assessments, and (4) diagnosis, evaluation, or treatment of symptoms of an acute stroke.
