---
title: "Originating Site vs Distant Site in Telehealth"
description: "The originating site is where a telehealth patient is, the distant site where the clinician is. Why licensure follows the patient and how Cuvo Health routes."
canonical: "https://cuvo.co/glossary/telehealth-originating-site"
last-updated: "Oct 26, 2026"
---
**Definition:** In telehealth, the originating site is where the patient is located when a service is delivered, and the distant site is where the treating clinician is located. State licensure follows the originating site: the clinician must be authorized to practice in the patient's state.

# What are the originating site and distant site in telehealth?

Every telehealth visit has two locations, and the law cares most about the patient's. Medicare named them the originating site and the distant site, and state licensure follows the first. Cuvo Health captures each patient's location at intake and routes the visit only to a provider licensed there.

Published Oct 26, 2026. Facts reviewed Oct 26, 2026.

In telehealth, the originating site is where the patient is located when a service is delivered, and the distant site is where the treating physician or practitioner is located. Medicare defines both terms in 42 CFR 410.78, and the distinction decides more than billing: state licensure follows the originating site. The Interstate Medical Licensure Compact Commission says the location of medical practice is the state where the patient is located, and the Nurse Licensure Compact says nurses must be licensed in the state where the patient is located at the time of service. Cuvo Health captures each patient's location at intake and routes the visit only to a provider licensed there, across all 50 states, DC, Puerto Rico, Guam and the US territories.

**At a glance**
- Originating site: Where the patient is located at the time of the service (42 CFR 410.78(a)(4))
- Distant site: Where the physician or practitioner is located at the time of the service (42 CFR 410.78(a)(2))
- Licensure: Follows the patient's state, not the clinician's or the company's
- Medicare payment: Limits which originating sites qualify, with exceptions such as the home for listed services
- Exceptions: Narrow and state-specific, such as an existing patient temporarily in the District of Columbia
- On Cuvo: Patient location captured at intake; each visit routed only to a provider licensed there

**Which location decides what in a telehealth visit (sources checked October 26, 2026)**

| Question | Decided by | Rule |
| --- | --- | --- |
| **Which state's license the clinician needs** | The originating site | Practice occurs where the patient is located (IMLC and NLC guidance) |
| **Which state's practice rules apply** | The originating site | All laws and regulations of the patient's state apply (IMLC) |
| **Whether Medicare pays for the visit** | Both sites | Originating site type and location, plus the distant site practitioner (42 CFR 410.78(b)) |
| **Where the brand is headquartered** | Neither | Does not change the license a visit needs |

## 01. Why does the originating site matter for a telehealth brand?

Because the patient's location, at the moment of the visit, decides which state's license the clinician needs. A brand that sells nationally has patients in every state, and a patient who signs up at home and opens a follow-up visit while traveling is at an originating site in the state they are traveling in. Some states carve out narrow exceptions: D.C. Code 3-1201.05(e), for example, lets a clinician without a District license treat an existing patient who is temporarily in the District. Exceptions like that are state-specific, so a program plans on a licensed provider for every state its patients can be in.

## 02. How is an originating site different from a distant site?

The originating site is the patient's end of the visit; the distant site is the clinician's. Medicare's definition of asynchronous store and forward technology uses both: the patient's medical information is transmitted from the originating site to the physician or practitioner at the distant site, who reviews the case without the patient present. The distant site practitioner must be licensed to furnish the service under state law (42 CFR 410.78(b)(1)), which in practice means licensed where the patient is.

## 03. Do Medicare originating site rules apply to every visit?

No. The site lists in 42 CFR 410.78(b) are conditions of Medicare Part B payment. The regulation names eligible originating sites, such as a physician's office, a hospital or a rural health clinic, adds the patient's home for listed services such as substance use disorder treatment and home dialysis assessments, and sets rural location requirements with exceptions. A visit that is not billed to Medicare is not governed by those payment conditions, but the licensure rule applies to every visit, whoever pays.

## 04. How does a telehealth platform handle patient location?

It asks where the patient is at the time of the visit, not only where the patient lives, and routes the visit to a clinician licensed in that state. On Cuvo, the patient's location is captured at intake and each visit, asynchronous or live video on every plan, is routed only to a provider licensed where the patient is located. The brand never recruits a provider, files a license or tracks a renewal.

## Frequently asked questions

**Q: What is an originating site in telehealth?**

A: It is the location of the patient at the time a telehealth service is delivered, as Medicare defines it in 42 CFR 410.78. On Cuvo, the patient's location is captured at intake so each visit routes to a provider licensed there.

**Q: Originating site vs distant site: what is the difference?**

A: The originating site is where the patient is; the distant site is where the treating clinician is. Licensure follows the originating site, which is why Cuvo Health routes every visit only to a provider licensed in the patient's state.

**Q: Does a telehealth provider need a license in the patient's state?**

A: Generally yes: both licensure compacts treat practice as occurring where the patient is located, and states allow only narrow exceptions. Cuvo Health's network holds licensure across all 50 states, DC, Puerto Rico, Guam and the US territories for exactly this reason.

**Q: Can a patient's home be an originating site?**

A: Yes. For Medicare payment, 42 CFR 410.78 lists the home as an eligible originating site for listed services, including substance use disorder treatment, and outside Medicare the home is simply where the patient is located. On Cuvo, visits run asynchronously or by live video wherever the patient is.

**Q: Does a telehealth brand need to track patient location?**

A: Yes, because the patient's location at the time of the visit decides which state's license the clinician needs. On Cuvo, location is captured at intake and routing handles the match automatically, at $25 per completed consult.

**Related pages**

- [Interstate Medical Licensure Compact (IMLC)](/glossary/interstate-medical-licensure-compact): How physicians add state licenses
- [IMLC states in 2026](/compliance/imlc-states): Which states issue compact licenses
- [Async vs sync telehealth](/blog/async-vs-sync-telehealth): Store and forward or live video
- [Telehealth licensing and credentialing across all 50 states](/blog/fifty-state-provider-network): Licensure where the patient is, in depth
- [The 50-state provider network](/provider-network): Coverage and visit routing
- [Telehealth glossary](/glossary): Every term a telehealth founder meets

Canonical page: https://cuvo.co/glossary/telehealth-originating-site