By Kimberly Maupin, CPC, and Briauna Driggers
Teleradiology has transformed healthcare by enabling radiologists to provide critical diagnostic services from any location, addressing provider workforce shortages, as well as increasing accessibility and efficiency. However, with these advancements come complex compliance challenges, particularly in state licensure, coding, and reimbursement.
What is teleradiology?
Teleradiology is a type of telehealth that involves the transmission of medical images, such as radiological exams (X-rays), computed tomography (CT) scans, or magnetic resonance imaging (MRI) scans from one location to another, for remote interpretation by the provider. Teleradiology eliminates travel for providers and can reduce costs; however, specific policies for teleradiology must be considered when reporting these services.
Provider Location – United States or Out-of-country?
Radiologists can either provide teleradiology services internally for a current employer or be contracted with a company that provides teleradiology services for multiple organizations, upon request. Contracted Radiologists may be either based in the United States or located in another country.
Teleradiology compliance considerations can vary depending on the specific scenario. For example, while Medicare may reimburse final interpretations performed by a contracted Radiologist who is based in the United States, they will not reimburse final interpretations performed by a contracted Radiologist who is located in another country. While many commercial payers do choose to follow Medicare policies, there are some commercial payers that create their own policies which must be consulted individually to determine coverage and reimbursement.
Multi-state Licensure Requirements
The Centers for Medicare and Medicaid Services (CMS) and the American College of Radiology (ACR) have differing policies regarding physician state licensure for teleradiology.
The Medicare Program Integrity Manual, Chapter 10, Section 10.3.1.4.3 states that the physician or non-physician practitioner (NPP) that provides the interpretation and written report is not required to be licensed in the state where the radiology exam was performed. The performance of the radiology exam itself is known as the “technical component,” while the interpretation of the radiology exam by the physician or NPP into a written report is known as the “professional component.”
The ACR policies require the physician or NPP to be licensed in both the state where the radiology exam was performed (where the patient is located when the technical component of the exam is performed) and the state where the interpretation takes place (where the physician or NPP is located when the professional component is performed).
Many Radiologists follow the stricter ACR policy and become licensed in all states involved in the teleradiology service. Although this is a sure-fire way to ensure compliance, each individual state has its own policies regarding out-of-state licensure for physicians providing teleradiology services. Individual state requirements should be consulted to ensure appropriate compliance with all policies. In addition to states licensure, the out-of-state physician may also be required to be credentialed and hold the appropriate privileges at the hospital for which they are providing the teleradiology service.
POS and Correct Reimbursement Rates
The place of service (POS) reported on the claim form for a teleradiology service should be where the technical component was performed. The address where the interpretation took place (the professional component where the radiologist or NPP was sitting when interpreting the radiology exam) should be entered in box 32 on the CMS 1500 claim form. The correct address must be reported in box 32 to ensure proper reimbursement rates are received from the appropriate Medicare Administrative Contractor (MAC).
CPT® Coding
There are currently no CPT® codes specific to teleradiology. These services should be reported using the appropriate radiology CPT® code for the service provided within the existing code set (e.g. 70450 for a CT of the head without contrast).
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