APA WF # 26-02 Telehealth Originating Site Reimbursement

The proposed policy changes are being promulgated as Emergency and Permanent Rules.

The proposed revision adds a facility fee for originating sites when a member receives services via telehealth. The fee is payable to the physical site hosting the member, separate from the distant-site provider’s professional claim. Eligible sites include hospitals, outpatient departments, physician and practitioner offices, RHCs, FQHCs, I/T/U clinics, and public health clinics. The fee is only allowed when the site provides staff or facility resources to support the encounter. It is not reimbursable when the member is at home or when no resources are used. Equipment and transmission costs remain non-covered.

Please view the draft regulatory text here and submit feedback via the comment box.

Please view the rule impact statement here.

Proposed Policy Timeline

Circulation Date: 12/15/2025

Medical Advisory Committee: 1/8/2026

Comment Due Date: 1/15/2026

Public Hearing: 1/15/2026

Board Meeting: 1/21/2026

After you submit your comment, you should be re-directed to a confirmation page. If you are not, please submit your comment through e-mail to federal.authorities@okhca.org.

Please note that all comments must be reviewed and approved prior to posting. Approved comments will be posted Monday through Friday between the hours of 7:30 a.m. – 4 p.m. Any comments received after 4 p.m. will be posted on the following business day.

Cynthia: 

The Telehealth Alliance of Oklahoma supports the addition of an originating site facility fee. We do seek clarification and revisions.

1. We request that the list be expanded to include those facilities that are also eligible for an originating site fee under Medicare: critical access hospitals, rural emergency hospitals, skilled nursing facilities, community mental health centers, hospital-based or critical access hospital-based renal dialysis centers, and renal dialysis facilities.

2. We request clarification around the terms “reasonable alternatives” and “close proximity.” It is not clear what would be considered a reasonable alternative to access care. The specific facts and circumstances of the patient’s care should be taken in account. We also request clarification of what distance is considered in “close proximity.”

3. The Rule Impact Statement for APA WF# 26-02 states that there is a new cross reference statement for school-based services to reflect the relocation of the school-based requirements from the telehealth section to the dedicated school-based services section. This language does not appear to be added. We request that 317:30-5-1020 be amended to reflect the school-based provisions.

OHCA Response:

Thank you for your comments and for your support of the addition of an originating site facility fee. The State made some revisions in response to your comment. The list of eligible originating sites now includes skilled nursing facilities, and the language describing when the fee is not reimbursable was revised to clarify reimbursement limitations based on access and timeliness of care.

A separate rule revision addressing telehealth in a school setting had been planned; however, the State determined that no changes are needed at this time, and the telehealth provisions for services provided in a school setting will remain in this section.