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<strong>CMS</strong>-1403-FC<br />

indicated previously, under section 1834(m)(2)(A) of the<br />

Act, telehealth is a delivery mechanism for otherwise<br />

payable Part B services; that is, services which would be<br />

separately payable under Part B if “ . . . furnished<br />

without the use of a telecommunications system” (emp<strong>has</strong>is<br />

added). <strong>This</strong> means that distant site professional services<br />

can qualify for separate telehealth payment only to the<br />

extent that they are not already included within a bundled<br />

payment to the facility that serves as the originating<br />

site. Thus, services furnished to a SNF resident from the<br />

distant site by a physician, physician assistant, nurse<br />

practitioner, clinical nurse specialist, certified<br />

nurse-midwife, or qualified psychologist would be<br />

separately billable as telehealth services, as the services<br />

of all of these practitioner types are excluded from<br />

payment under the SNF PPS under section 1888(e)(2)(A)(ii)<br />

of the Act. However, the services of other practitioners<br />

such as clinical social workers (CSWs), registered<br />

dietitians, and nutrition professionals are subject to SNF<br />

consolidated billing when furnished to the SNF’s Part A<br />

resident. In order to avoid duplicate payment, telehealth<br />

services furnished by these practitioners would be<br />

separately billable telehealth services only in those cases<br />

872

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