telemedicine follow up visit cpt code

2024 Telehealth CPT Codes: Cheat Sheet

Charika Wilcox-Lee, VP, Revenue Cycle Management

Keeping track of telehealth reimbursements accurately directly impacts your healthcare organization’s bottom line. We’ve compiled a list of telehealth CPT codes to help you better navigate telehealth billing for your care program.

Source: American Academy of Sleep Medicine (AASM)

CMS Telehealth & RPM Billing Guidelines [PDF]

In recent years, the Centers for Medicare & Medicaid Services (CMS) have released the physician fee schedule with expanded reimbursement for remote patient monitoring (RPM). The guidelines notably increase reimbursement for other services like remote therapeutic care and chronic care management, while making slight adjustments to allowances for RPM.

Top 4 Common Telehealth Billing Mistakes—And How to Avoid Them

The surge of telehealth adoption in recent years has led to regulatory changes and telemedicine coverage expansion that greatly benefits healthcare providers—if reimbursement is done correctly. Here are the top four common mistakes when billing for telehealth, and how you can avoid them.

Mistake #1: Not keeping up with the correct billing codes

As Medicare regulations change in response to public healthcare needs, the billing codes that you’re already familiar with could change as well. Submitting claims with the wrong code could result in delayed reimbursement and in some worst cases, be flagged for abuse.

Avoid by : Staying up to date with additions or deletions to the list of Medicare telehealth services .

Mistake #2: Not maintaining post-visit documentation

Ensuring that you document the right information during telehealth visits is key to getting prompt payment. For a start, touch base with your administrative team to understand the type of information you should be keeping a record of.

Avoid by : Creating a checklist that you can go over before the telehealth visit for cross-checking purposes.

Mistake #3: Not training your team on telehealth billing processes

Your team already has to keep track of thousands of CPT codes on a daily basis. With the new batch of telehealth CPT codes added to the mix, things can easily get very complicated for your team.

Avoid by : Training your team on the types of codes, processes, and all things reimbursement.

Mistake #4: Not checking with the patient’s insurance beforehand

While most major private payers provide coverage for telemedicine, it’s prudent to call up the payer and confirm if the services offered are covered. The good news is, that you’ll only need to verify this once for that particular policy.

Avoid by : Being more diligent about checking insurance coverage before the patient’s first telehealth visit. Use an insurance verification form to log the call and make sure you’re asking the right questions.

8 Key Updates to Telehealth Reimbursement in 2024

CMS has   released its final rule   for Medicare payments under the Physician Fee Schedule (PFS), introducing significant changes that will impact healthcare providers across the country. To help you stay informed and prepared, we've compiled the eight key updates you need to know.

Telehealth Reimbursement Resources & Expert Support

At Health Recovery Solutions, we provide a host of resources on reimbursement and telehealth billing modeled after best practices that we established from working with our healthcare partners—and we’re ready to help. Whether you're in the early stages of researching the benefits of telehealth and remote patient monitoring for your patients or you have an existing program in place and you're considering options to maximize the value of RPM, our team of experts is here to support you. 

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Telemedicine Codes

Telemedicine and telehealth are used interchangeably throughout the United States healthcare system, in reference to the exchange of medical information from one site to another through electronic communication. Reporting of telemedicine/telehealth services varies by payer and state regulations.

AASM Telemedicine/Telehealth Resources

• AASM Coding FAQs
• AASM Telemedicine Video Library

CMS Telemedicine/Telehealth Codes

The codes below are commonly reported for Medicare patients:

CMS finalized the creation of two additional G codes that can be billed by practitioners who cannot independently bill for E/M services. G2250 and G2251 are billable by certain non-physician practitioners, consistent with the scope of these practitioners’ benefit categories.

CPT Telemedicine Codes

Modifier 95 indicates a synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system. The 2020 CPT® manual includes Appendix P, which lists a summary of CPT codes that may be used for reporting synchronous (real-time) telemedicine services when appended by modifier 95. Procedures on this list involve electronic communication using interactive telecommunications equipment that includes, at a minimum, audio and video.

HCPCS LEVEL II CODES

There are also HCPCS Level II codes that describe telemedicine services.

Place of Service (POS) Code for Telemedicine

On January 1, 2017 the Center for Medicare and Medicaid Services (CMS) introduced place of service (POS) code 02 to identify telemedicine services. The descriptor for POS code 02 is “The location where health services and health related services are provided or received, through telecommunication technology.” Use of the telehealth POS code certifies that the service meets all of the telehealth requirements. Many private payers have also begun requiring use of POS code 02 for telemedicine services.

GT/GQ Modifiers

Medicare previously required providers to submit claims for telehealth services using the appropriate procedure code along with the telehealth GT modifier (“via interactive audio and video telecommunications systems”) or GQ modifier (“via an asynchronous (delayed communications) telecommunications system”). As of January 1, 2018, the GT modifier is only allowed on institutional claims billed under Critical Access Hospital (CAH) Method II since institutional claims do not use a POS code. If the GT modifier is billed by other provider types, the claim line will be rejected. The GQ modifier is still required when applicable (e.g., for those providers participating in the Alaska or Hawaii federal telemedicine demonstration programs).

Additional CMS Telemedicine/Telehealth Resources

• Complete list of CMS Telehealth Services
• General Provider Telehealth and Telemedicine Toolkit
• Medicare Telehealth Frequently Asked Questions (FAQs)
• Medicare Telehealth Services

Note: CPT Copyright 2021 American Medical Association. All rights reserved. CPT® is a registered trademark of the American Medical Association.

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Coding Telemedicine Visits for Proper Reimbursement

Gary n. gross.

Internal Medicine, Southwestern Medical Center, University of Texas, Dallas, TX USA

Purpose of Review

Coding for patient visits and monitoring via telehealth have expanded over the past years with a wide acceptance of telemedicine as a consequence of the coronavirus pandemic. Coding topics of interest to the allergist/immunologist in regard to services provided via telemedicine will be of increasing importance in the coming years.

Recent Findings

CPT coding for telephone as well as synchronous face-to-face telehealth visits has changed over the past few years. With the need for distancing and patient protection during the coronavirus pandemic, telehealth services have increased dramatically. The introduction of newer devices to remotely monitor patients will increase and be incorporated into patient care.

This review will summarize current codes available for designating what services have been provided. The area of telemedicine is changing and will continue to evolve as other platforms for visits are designed and other methods of monitoring patients become available. Coding for these services will be an ongoing need for the provider.

Introduction

Current procedural terminology (CPT) has recognized the need for designations of procedures done using technology. Although initial codes focused primarily on telephone visits, in 2017, CPT recognized a new place-of-service (POS) code designating “The location where health services and health related services are provided or received, through a telecommunication system.” This POS “02” was a step forward in awareness of the need for distant patient encounters and procedures. Further codes for both monitoring and evaluating via telehealth will be discussed. Table ​ Table1 1 lists current CPT codes available for designating services provided.

Current CPT codes [ 1 ]

Telehealth Coding

Two words must be remembered whenever coding is discussed. The two words, “it depends,” define the lack of consistency in coding throughout the industry. Coding is generally driven by The Centers for Medicare & Medicaid Services (CMS) and CPT (although they do not always align). CPT codes exist for procedures, but some carriers may not recognize or reimburse for the codes [ 2 ]. Some carriers may create their own limits on reimbursing for codes, arbitrarily considering procedures bundled with evaluation and maintenance (E&M) visits. Codes may be paid for certain disease states but not for others. Insurers vary with regard to expectations of what place-of-service to use or how to bill for some procedures. New modifiers for telehealth visits further complicate billing. The modifiers –GT and -95 are used by some carriers for telehealth visits and vary depending on the insurer. Similarly, place of service may be either “02,” the telecommunication POS mentioned above, or remain “11” which designates the office location. Therefore, one must be flexible and informed. Keeping track of each carrier’s latest provider information and appealing denials with alternative codes may be necessary.

As with conventional patient encounters, documentation is key. For telehealth visits, there is also the need to document the patient’s consent for the encounter via telehealth. Most of the telehealth codes are for providers who could bill for evaluation and management (E/M) services such as physicians, physician assistants (PAs), and nurse practitioners (NPs). These providers are considered qualified healthcare providers (QHP).

Non-face-to-face Telehealth Patient Visits

Telephone services (99441–99443).

These codes are non-face-to-face E/M services used by QHP. They are designed for telephone calls initiated by an established patient and have certain restrictions. If the call includes the decision to see the patient in the next 24 h or next available urgent appointment, it cannot be billed. Similarly, if the call refers to an E/M service reported by the QHP within the past 7 days, the telephone codes cannot be used. Thus, these calls are initiated by the patient or guardian of the patient and stand apart from other E/M visits as described.

• 99441 - 5–10 min of medical discussion
• 99442 - 11–20 min of medical discussion
• 99442 - 11–30 min of medical discussion

An established patient, who has not been seen in the past month, calls the office because of a recent ant bite. The patient wants to speak to the physician since the physician also treats the son for anaphylaxis to wasps and the patient is concerned. The physician talks to the patient about the kinds of reactions that might occur and notifies him of what symptoms he should be aware of. Out of an abundance of caution, the physician reminds the patient about using an epinephrine autoinjector. The conversation takes 25 min. The staff calls in the autoinjector to the pharmacy and is on the phone for 15 min waiting for the pharmacist.

The patient is billed 99443 for the physician time. The staff time would not enter into the total time. The note in the chart would document that the visit was via telephone and that the patient called the clinic about the problem. The discussion would be documented and the note would indicate the patient had not been seen and no E/M visit was anticipated. The note would also indicate that 25 min was spent in discussion.

Online Digital Evaluation and Management Services (99421–99423)

These codes are electronic communication codes. The problem may be new to the physician or QHP but the patient must be established. These services are patient-initiated through HIPAA-compliant secure platforms or portals.

These services include evaluation, assessment, and management of the patient.

These services are reported once during a 7-day period and therefore time is cumulative.

The time includes (1) review of the initial inquiry, (2) review of patient records or data pertinent to assessment of the patient’s problem, (3) interaction with clinical staff focused on the patient’s problem and development of management plans, (4) physician or other QHP generation of prescriptions or ordering of tests, and (5) subsequent communication with the patient through online, telephone, email, or other digitally supported communication, which does not otherwise represent a separately reported E/M service.

These services require permanent documentation storage (electronic or hard copy) of the encounter.

If within 7 days of the initial patient-initiated contact a separate E/M visit (in person or synchronous telemedicine) occurs, then the Online Digital visit is not billed but the time is incorporated into the subsequent E/M visit. If the Online Digital visit is initiated within 7 days of a previous E/M visit for the same or related problem, the Online Digital visit is not reported. If a new or different problem is being addressed in the Online Digital visit, then the visit is billable and should be reported.

• 99421-5–10 min (over a 7-day period)
• 99422-11–20 min (over a 7-day period)
• 99423-21 or more minutes (over a 7-day period)

Remember that only physician or other QHP time is used in the calculation. Staff time is not included.

An established patient who was seen 3 days ago for allergic rhinitis wakes up with hives. She uses the practice’s HIPAA compliant portal to message her doctor about the hives. The PA responds to the message and gathers information about the hives, the patient’s activities, and ultimately prescribes an antihistamine. The encounter takes 10 min. Two days later, the patient messages again saying the hives are better but not gone. She wants stronger medicine. The PA responds to the message and offers to prescribe a short course of corticosteroids. The PA describes the possible side effects of the steroids and also tells the patient what should be done if the hives do not clear. The PA spends 12 min with the encounter. The patient does not call back and does not come to the office for the hives. The PA bills the patient 99423 since the sum of the two encounters was 22 min within a 7-day period and the hives were not related to the allergic rhinitis the patient had been seen for 3 days before the hives.

The chart would document that the patient contacted the clinic for a new problem. All time spent by the PA would be documented to support the total time billed. It would be documented that no E/M visit was anticipated for this new problem.

Healthcare Common Procedure Coding System (HCPCS) have 2 levels of commonly used codes. Level 1 codes are CPT codes and level 2 codes are alphanumeric codes. One group of HCPCS codes are “G codes.” The G codes are used to identify professional healthcare procedures and services that would otherwise be coded in CPT but for which there are no CPT codes. Two “G codes” are relevant to telehealth and do not yet have matching CPT codes [ 3 ].

was in the 2019 physician fee schedule and is used for remote evaluation of established patient’s submitted videos or still images. The purpose of the evaluation is to determine whether or not an E/M visit is necessary. It may be billed if the evaluation does not lead to an E/M visit and does not occur within 7 days of a previous E/M visit. To bill for the evaluation, the physician or other QHP must evaluate the image within 24 business hours and follow-up with the patient in the form of a 5–10 min discussion with the patient.

An established patient develops a rash and is uncertain about its cause. The patient sends the physician a picture of the rash. The physician evaluates the photo and determines it is a hive. The physician calls the patient and tells him that these are common and if they last more than 6 weeks or get worse he can check back, but that he does not need to have an E/M visit.

Documentation of this remote evaluation would include the picture in the chart and the provider’s note that the picture was viewed and that no visit would be necessary unless the hives lasted more than 6 weeks. The presumed diagnosis of acute urticaria would also be included.

was also included in the 2019 physician fee schedule. It has been referred to as a “virtual check-in.” It is considered to be a call or video check in to see if an E/M visit is needed. Similar to some other e-codes, it cannot be billed if there was a related E/M service within the previous 7 days or it leads to an E/M visit within the next 24 h or soonest available appointment. The code is used for established patients having direct interaction with the billing practitioner (not the staff). The service must be medically reasonable and necessary but there is no limitation on frequency. The code assumes 5–10 min of medical discussion.

An established patient calls the nurse practitioner and describes a large, local reaction they have from a mosquito bite. The patient wants to know if they need to come in or go to the ER. The nurse practitioner informs the patient about the type of reaction and tells the patient they only need to come in if they have trouble breathing or if the reaction spreads. The patient is reassured and watches the reaction as it gradually goes away. The practitioner can bill G2012.

The documentation for this virtual check in would include the main points of discussion including the bite and the likely diagnosis as well as the 5+ min the provider is on the platform talking with the patient.

Face-to-face Telehealth Patient Visits

The Centers for Medicare & Medicaid Services (CMS) defines telehealth services to include those services that require a face-to-face meeting with the patient. These are visits commonly considered “office visits” but delivered via synchronous audio and video contact with the patient. The usual E/M visit codes (99201–99215) would apply.

Prior to 2021, these E/M visits level of service was determined by history, physical exam, and medical decision-making as documented in the CPT book each year. If more than 50% of the face-to-face time with the patient and/or family was used in counseling and/or coordination of care, time becomes the key factor in determining level of service.

Beginning with CPT 2021, time alone may be used to select the appropriate level for the office or other outpatient E/M services codes (99202, 99203, 99204, 99205, 99212, 99213, 99214, 99215). This “time” requires a face-to-face encounter with the physician or other QHP. Time spent with staff such as registering in the office or making future appointments is not used in the calculation of time. Also, note that the new patient level one code (99201) has been deleted.

Medical decision-making (MDM) includes establishing diagnoses, assessing the status of a condition, and/or selecting a management option. Beginning in 2021, MDM may be used independently in establishing a level of service (without consideration of history or physical exam as was required previously). These changes were designed to reduce duplication and unnecessary, repetitious documentation, and should also make coding for telehealth E/M visits easier.

The telemedicine E/M visits are coded just as an in-office E/M visit would be but possibly with the addition of a modifier or a different place of service code depending on the insurance company. Some provisions for telemedicine have been waived during the pandemic to allow more patients access to medical care and to avoid exposure to others in waiting rooms and offices. The telemedicine waivers include evaluation of new patients via telehealth, beneficiaries living in any geographic area and accessing telemedicine from their homes, and use of smartphones and audio only connections for some services. Whether all these waivers will remain in place following the pandemic is unknown.

An established patient calls the office to set up an appointment and is offered a telemedicine option. The patient finds this attractive since it will save him time in traffic and reduce his time away from work. It is for a follow-up to see how he is doing after starting immunotherapy a month ago. The patient signs into the doctor’s telehealth platform and gives verbal consent for the visit. They discuss symptoms, reactions to injections, medications, and concerns of the patient regarding future injections if he goes on vacation. The face-to-face time with the physician is 22 min and the code billed is 99213 (less than the minutes currently typical for 99214 and within the 20–29 min designated for 2021).

These telemedicine visits will require documentation similar to in-person visits. They will include the notation that the patient consents to the telehealth visit. Since the visits for new patients require physical examinations, the best way to document and bill these visits will be based on time. Until 2021, the notation that over 50% of the time with the patient was related to counseling and/or coordination of care is also needed. For follow-up visits before 2021, only two major components of the E/M visit are necessary, so history and medical decision-making with documentation could be used. It may be easier since most telemedicine visits are largely counseling and coordination of care, to base these encounters on total time also and indicate that greater than 50% was devoted to counseling/coordination of care. Typical documentation will include the consent for the visit, the discussion with the patient, the differential diagnosis, the plan of care, and the total “face-to-face” time spent on the visit. The further notation that > 50% of the time was related to counseling and coordination of care (assuming it was) should also be documented.

Remote Monitoring

In addition to patient encounters whether non-face-to-face or face-to-face, the allergist/immunologist may also do remote monitoring of the patient. The 2020 CPT book lists the following codes for remote patient monitoring (RPM). Although some requirements for telehealth services have been modified during the pandemic, RPM services have never been limited by geography to rural or medically underserved areas, nor is there any “originating site” restriction for RPM services. In fact, RPM services can be provided anywhere the patient is located, including at the patient’s home.

• 99453 Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment
• 99454 Device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days (provided monitoring occurs at least 16 days during the 30-day period)
• 99457 Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 min.
• 99458 Each additional 20 min

As more devices become available to monitor asthma and other diseases treated by the allergist/immunologist, these codes will become more widely used just as blood pressure monitoring and diabetes monitoring are today.

An established patient is in the office and has poorly controlled, moderately severe persistent asthma. You provide the patient with a home spirometer that will transmit the FEV1 and FVC to your office. The patient is instructed on how to set up and use the device. He provides data via the portal for 20 days of the next month and you and your staff retrieve the data and analyze it. The time involved in retrieving and analyzing the information is 18 min. You modify the patient’s treatment program and describe the new treatment program during a telemedicine visit.

Billing would be 99453, 99454, and 99457 (each one unit). The E/M visit would be billed based on the time spent with the patient in describing the new treatment plan.

The documentation for these services might include a statement such as “we have provided this patient a remote spirometer and taught the patient its proper use. The patient has used it and transmitted information to us 20 days this month and the staff and I have spent 18 min total in the monitoring and responding to this patient in regard to asthma management based on results of the information transmitted.”

An older CPT code used for remote patient monitoring is 99091. This older code requires 30 min to bill based on a 30-day period. It is also limited to physicians and QHPs. There must be a face-to-face visit within 1 year and consent must be given and documented. The platform used must both collect and transmit data in real time or near real time to be eligible.

Another set of spirometry codes (94014, 94015, 94016) relate to patient-initiated remote spirometry, transmission of tracings, and review and interpretation by a physician or QHP. The second code (94015) does not include review and interpretation by a physician or other QHP whereas the third code (94016) is the review and interpretation by the provider. 94014 is an inclusive code of the latter two.

Interprofessional Telephone/Internet/Electronic Health Record Consultations

Codes 99446, 99447, 99448, 99449, and 99451/99452 are used to report a consultation when there is an interprofessional electronic consultation regarding assessment and management of a patient who is not seen face-to-face by the consulting provider. The patient may be a new patient to the consultant or an established patient with a new problem. The patient should not have been seen by the consultant for a face-to-face encounter in the past 14 days. Similarly, there should not be a transfer of care or a face-to-face encounter within the following 14 days of the consultation. Greater than 50% of the time for service must be devoted to the verbal or internet discussion. These codes should not be reported more than once within a 7-day interval. The consulting provider delivers a written or verbal report to the patient’s treating provider. The patient or family must give verbal consent (documented in the record) for the consult.

• 99446 reported by the consulting provider for 5–10 min of consultative discussion/review
• 99447 11–20 min
• 99448 21–30 min
• 99449 31 min or more

Code 99451 is reported by the consultant for 5 min or more time but does not require that more than 50% of the time be consultative time as opposed to data review. Furthermore, 99451 requires a written report.

Code 99452 is billed by the treating/requesting provider. This code is for time spent in preparing the consult and/or time communicating with the consultant for 16 min or more time.

Conclusions

Telemedicine will continue to be a significant part of the allergy/immunology practice even after the pandemic. Both Medicare and commercial insurance companies have made special provisions for telehealth during the pandemic in order to make medical care more readily available for patients who are concerned about their symptoms and also concerned about possible exposure to illness in a healthcare facility. Such provisions as allowing telephone calls (without video) to be sufficient for a “face-to-face” telemedicine visit for patients who do not have access to computers or other means of communicating via video connections will probably not continue after the pandemic [ 3 , 4 ]. The leniency on what platforms can be used by practices for telehealth visits will also likely change after the pandemic. These possible changes will likely be rolled out at different times for different carriers so it will be critical to review EOBs and look at insurers’ websites and newsletters.

It will be important to learn the codes and understand what codes different insurers require in order to be properly reimbursed for your work. Remembering to get consent for visits, to document what was done, to adhere to procedures that are medically necessary, and to code correctly will help practices receive payment for these services. It would be helpful to medicine in general if the commercial insurance companies and CMS provided a uniform approach and guideline for telemedicine coding. Until such time that these stakeholders provide a consistent and uniform coding guide to telemedicine, remember that “it depends” as you select the appropriate code, modifier, and place of service for telemedicine encounters.

Compliance with Ethics Guidelines

The authors declare no conflicts of interest relevant to this manuscript.

This article does not contain any studies with human or animal subjects performed by any of the authors.

This article is part of the Topical Collection on Telemedicine and Technology

Publisher’s Note

Springer Nature remains neutral with regard to jurisdictional claims in published maps and institutional affiliations.

Coding Scenario: Coding for Telehealth Visits

Telehealth Visits

Note: These tables are informational, not advisory. The AAFP recommends that physicians verify each payer's policy and ask patients to verify their coverage ahead of appointments.

How do I code a new or established patient telehealth visit that uses audio-video or audio-only for COVID-19-related care?

* Anthem's policies vary by state; contact your provider-relations representative.

*Medicare requires audio-video for office visit (CPT 99201-99215) telehealth services. Audio-only encounters may be billed using the appropriate Telephone Evaluation and Management code.

How do I code a new or established patient telehealth visit that uses audio-video or audio-only for non-COVID-19-related care?

**Medicare and UHC Medicare Advantage require audio-video for office visit (CPT 99201-99215) telehealth services. Audio-only encounters may be billed using the appropriate Telephone Evaluation and Management code.

Telehealth Scenario Notes

A full list of Medicare telehealth services is available here . Private payers vary on covered telehealth services. Check with your provider relations representatives for each payer’s telehealth policy and covered telehealth services.

Telehealth services can be provided to new and established patients via smartphone if the smartphone allows for audio-video interaction between the physician and patient.

Originating site restrictions have been lifted. Telehealth services can be provided to all patients regardless of originating site, including patients at home.

Office visits provided via telehealth will be paid at the same rate as in-person visits when the appropriate POS is used. Practices should use the POS they would have used if the service had been provided in-person. Claims with “POS 02 – Telehealth” may be paid at a lower rate.

• Some payers are automatically reprocessing claims that were submitted with the “POS 02 – Telehealth.” Contact your provider relations representative to verify if the payer is automatically reprocessing claims or if you will need to resubmit claims.

Medicare and most national payers will pay the full contracted/allowed amount when cost-sharing is waived. The “CS” modifier is required to trigger full payment of the allowed amount. Claims missing the “CS” modifier may not be paid at the full allowed amount.

COVID-related services include:

• An in vitro diagnostic test for the detection of SARS-CoV-2 or the diagnosis of COVID-19. The test must be approved, or the developer has requested or intends to request emergency use authorization under the Federal Food, Drug, and Cosmetic Act;
• a test that is developed in and authorized by a state that has notified the secretary of Health and Human Services (HHS) of its intention to review tests intended to diagnose COVID-19; or
• other tests the secretary of HHS determines appropriate in guidance.
• Items and services furnished to an individual through office visits (in-person and telehealth), urgent care center visits, and emergency room visits that result in an order for or administration of a COVID-test. Items and services must be related to the furnishing or administration of the test or to the evaluation of the patient for the purposes of determining the need for a COVID-19 test.

COVID-19-related services should be assigned the appropriate COVID-19 ICD-10 diagnosis code. Coding guidance can be found on the CDC website . Cost-sharing waivers may not be applied to claims that do not include an appropriate COVID-19 ICD-10 diagnosis code.

Some payers are allowing practices to provide telehealth office visits to provide using audio-video or audio-only communications. These visits should be coded as a typical telehealth visit as outlined above.

• The applicable coding requirements must be satisfied for the visit. Physicians should determine whether they can complete all required elements of their normal E/M service via audio only or whether the services should be submitted as a telephone E/M code.
• Aetna will cover minor acute care services delivered via audio-only.
• UHC will allow audio-only visits telehealth services for Medicaid and commercial patients. The requirements for Medicare Advantage members align with Medicare’s policy (below).
• Medicare requires audio-video for office visit (CPT 99201-99215) telehealth services. Audio-only encounters can be provided using the telephone evaluation and management codes (CPT codes 99441-99443) .

CMS has updated the documentation requirements for outpatient E/M services delivered via telehealth.

• Time is defined as all time associated with the E/M on the day of the encounter. This is similar to the updated guidelines for office/outpatient E/M codes scheduled to go into effect January 1, 2021.
• Physicians should use the times listed in the 2020 office/outpatient E/M code descriptors when using time to select the level of service.
• CMS is maintaining the current definition of MDM.
• CMS has removed any requirements regarding documentation of history and/or physical exam in the medical record for such visits.

If exchanged asynchronously, videos, images and communications must be stored and retained according to state regulation.

Real-time (synchronous) videos, such as during a video visit or video phone call, are not required to be stored.

Self-funded plans can develop their own policies and may opt out of some cost-sharing waivers. Similarly, Medicaid policies are established at the state level. The AAFP recommends reaching out to your provider relations representatives or Medicare Administrative Contractors (MACs) to verify policies. The Center for Connected Health Policy is tracking COVID-19 Related State Actions

Annual Wellness Visits

The Medicare AWV codes (HCPCS codes G0438 and G0439) are on the list of approved Medicare telemedicine services. CMS states that self-reported vitals may be used when a beneficiary is at home and has access to the types of equipment they would need to self-report vitals. The visit must also meet all other requirements. Commercial and private payers may have different policies. Please check with your provider relations representatives for additional guidance.

Federally Qualified Health Centers and Rural Health Clinics

CMS has released guidance allowing federally qualified health centers (FQHCs) and rural health clinics (RHCs) to provide distant-site telehealth services. Telehealth services can be provided by any practitioner working for the FQHC or RHC within their scope of service, and there are no restrictions on where the service is provided, meaning physicians or practitioners may provide the service from their homes.

The payment rate for telehealth services furnished by an FQHC or RHC practitioner is $92. FQHCs and RHCs must use the -95 modifier for distant-site services provided between Jan. 27 and June 30, 2020. FQHCs will be paid their Prospective Payment System (PPS) rate, and RHCs will receive their all-inclusive rate (AIR). Claims will be automatically reprocessed in July, when the Medicare claims processing system is updated with the new rate.

For distant-site services provided between July 1, 2020, and the end of the COVID-19 public health emergency, FQHCs and RHCs should use HCPCS code G2025 to identify the services furnished via telehealth.

CMS is waiving cost-sharing for services related to COVID-19 testing, FQHCs and RHCs should append the -CS modifier to claims related to COVID-19 testing. Coinsurance should not be collected from beneficiaries when cost-sharing is waived. MACs will automatically reprocess these claims beginning on July 1.

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Virtual-Digital

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Telehealth for emergency departments

Telehealth for follow-up care.

Telehealth technology can be used to provide follow-up care for patients who were triaged but not sent to the emergency department, or for patients after they are discharged from the emergency department.

On this page:

Getting started.

Telehealth technology can be used for simple follow-up communication through audio, video, email, text messages, and even chatbots. You may also choose to use remote patient monitoring (RPM) devices. Some RPM devices record patient vitals automatically through a wearable device, while others require patients to report their readings through an online tool or by talking with their provider.

Including follow-up care services in your telehealth program is especially important because patients who don’t follow emergency department guidance are more likely to be readmitted, putting them at higher risk of health complications. This can result in increased utilization and cost burden on the emergency department.

Benefits of using telehealth for follow-up care:

• Provides an opportunity to further engage with the patient to perform more assessments, talk to family members, ensure they understand their follow-up instructions about medications, and encourage them to schedule any referral appointments
• Provides additional care to patients who need observation but aren’t so sick that they need constant care
• Detects potential problems and treats them before they warrant a return visit to the emergency room
• Provides emotional support, especially for patients in isolation
• Provides a training opportunity for resident physicians
• Reduces hospital costs associated with unnecessary readmissions and CMS penalties for readmission for certain conditions

Using telehealth for follow-up care is especially important during COVID-19 to help:

• Follow up with lower-acuity COVID-19 patients, allowing them to stay in the comfort of their home and not take up beds or other emergency department resources
• Encourage patients to stay up-to-date with routine vaccinations and COVID-19 vaccinations

In addition to the items on the getting started  page, consider:

• What follow-up services you will offer, including use of remote monitoring devices
• Who will coordinate your follow-up workflow
• When you will schedule the first follow-up appointment — ideally done before or during discharge
• How you will help patients understand the process for follow-up services
• How you will communicate with the patient for their follow-up appointment — if you’ll be calling, let them know when to expect the call so they’re more likely to answer (some may avoid the call if they think it’s the billing department)
• How often you will communicate with the patient

If exploring remote patient monitoring, also consider:

• Which devices will easily integrate with your electronic health records (EHR) platform
• How you will manage HIPAA compliance
• If you need features that help you track time for billing and reimbursement
• If you need features to help remind patients when they are due to report data
• How you will provide support to keep the devices operational
• How you will train staff

More information about follow-up care:

• Coronavirus (COVID-19) Update: FDA allows expanded use of devices to monitor patients’ vital signs remotely  — from the U.S. Food and Drug Administration

Medical University of South Carolina

The Medical University of South Carolina (MUSC) adapted their existing telehealth program to respond to COVID-19. MUSC redesigned their virtual urgent care to screen patients for COVID-19 with the goal of providing a needed service while reducing risk by limiting exposure at the emergency department. Remote patient monitoring is used to support COVID-19 patients that could be treated at home. Existing continuous virtual monitoring technology was also adapted in high contagion risk areas so clinicians could manage patients virtually when appropriate while conserving PPE. Read more about the MUSC telehealth program  and how they adapted telehealth to respond to COVID-19 .

• Getting started telehealth  →
• Planning your telehealth workflow  →
• Preparing patients for telehealth  →

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Coding for Telemedicine

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What Is Telemedicine?

Regulatory requirements.

• Telemedicine rules apply to new and established patients.
• Patients must be notified that a claim will be submitted to the payer.
• Deductibles, co-payments and any remaining balances according to the remittance advice should be collected.
• HIPAA compliant platforms must be in place.
• Facebook Live, Twitch, TikTok, and similar video communication applications are public facing, and should not be used in the provision of telehealth by covered health care providers.

What Office Based CPT Codes Qualify for Telemedicine?

CMS made several services temporarily available as telehealth services for the public health emergency (PHE) on a provisional basis. This extension allowed CMS to collect usage data in support of possible inclusion as permanent additions to the Medicare telehealth services list. 

Beginning January 1, 2024, use place-of-service code (POS) 02-Telehealth to indicate you provided the billed service as a professional telehealth service when the originating site is anywhere other than the patient’s home. Use POS 10-Telehealth for services when the patient is in their home.

Telemedicine Phone Calls (Audio Only *)

Modifier application, hybrid exams.

• Staff obtains and documents history in the medical record.
• The patient is COVID-19 high-risk for severe illness; a telemedicine hybrid appointment is offered based on the clinic scheduling protocol.
• The physician reviews the chart and assesses the previous exam, visual acuity and findings.
• A retina OCT is ordered and documented in the medical record.
• The patient is scheduled for a visual acuity and OCT at the satellite office closest to her home.
• A subsequent telemedicine appointment with the ophthalmologist is scheduled at the next convenient date and time.
• At the satellite office, a technician tests visual acuity and conducts an OCT clinic, scheduled 30 minutes apart for social distancing. There is no wait for the patient and additional time is allotted for sanitation between tests.
• During the telemedicine appointment, the physician reviews the history, visual acuity, and OCT, discusses the findings and provides recommendations to the patient.
• After reviewing the patient’s chart and previous visual field and glaucoma OCT, the physician considers telemedicine options due to the lack of availability for a timely clinic appointment.
• The patient is scheduled for an IOP check at the next available drive-up clinic, with a follow-up telemedicine appointment with the physician.
• The follow-up telemedicine encounter is conducted. The physician reviews the IOP, discusses current medications and findings, and provides recommendations to the patient.
• Physicians should direct the scheduling of telemedicine hybrid encounters based on patient-specific criteria or a comprehensive clinical scheduling protocol.
• All delegated testing services require a physician order that is documented prior to the encounter.
• Patients must verbally consent to the telemedicine encounter.

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Coding Corner: Inpatient Consultations Via Telemedicine

With Sameer Sharma, MD, MBA, Society of Gynecologic Oncology (SGO) member and Director, Gynecologic Oncology at Northwest Cancer Center in Dyer, IN, and an Assistant Professor at Rush University in Chicago, IL.

Sameer Sharma, MD, MBA

Inpatient consultations via telemedicine can be used to substitute for a face-to-face encounter for initial and follow-up inpatient consultations, as well as for specialist consultations to discuss advice and recommendations physician-to-physician. These guidelines are constantly evolving during the COVID-19 public health emergency.

Initial Inpatient Consultations:

Medicare pays for reasonable and medically necessary inpatient telehealth consultation services furnished to beneficiaries in hospitals when your facility meets the following criteria for the use of a consultation code:

• The physician of record or the attending physician requests the initial inpatient telehealth consultation for their patients located in the hospital or emergency room and documents this in the patient’s medical record.
• A consultant or qualified health provider (QHP) needs to document the request for the inpatient telehealth consultation from an appropriate source and the need for an inpatient telehealth. The consultant then places this information in the patient’s medical record and lists the requesting physician.
• The visit can be performed with audio/video two-way communication; many states will also allow audio alone two-way communication.
• The consultant needs to prepare a written report of his/her findings and recommendations. Patient and QHP location should be listed in the record.
• Typically, these services are reported as telehealth services when the individual QHP is not at the same location as the beneficiary but there are no apparent limitations to the QHP location.
• The Medicare reimbursement for the consultation would include all related services furnished before, during, and after communicating with the patient via telehealth.
• Teaching Physicians: Under the so-called primary care exception at section, a teaching physician may meet the requirement to review a visit furnished by a resident remotely using audio/video real time communications technology.

These services include, but are not limited to: 

• Reviewing the patient’s diagnostic imaging and lab work
• Communicating with other physicians or family
• Documenting the visit in the patient’s chart
• Discussing the results of the telemedicine consultation
• Developing further care plans

The following codes should be used for an initial inpatient telemedicine consultation:

wRVU: work Relative Value Units

Follow-up Inpatient Consultations:

Telemedicine can be used to manage follow-up inpatient telehealth consultations  furnished to patients in hospitals. These encounters can only occur after the patient’s initial consultation.

• The visit can be performed with audio/video two-way communication; many states will also allow audio alone two-way.
• The initial inpatient consultation can be provided as either as an in-person encounter or a telemedicine visit.
• A subsequent inpatient visit can be furnished via Medicare telehealth, without the limitation that the telehealth visit is once every three days as per previous guidelines.

Follow-up inpatient telehealth consultations could include, but are not limited to, the following services: 

• Monitoring progress
• Suggesting management modifications
• Recommending a new plan of care based on changes in the patient’s status
• Coordinating care with other providers or agencies
• Communicating with other professionals
• Reviewing patient data
• Discussing the case with the patient’s family
• Completing medical records or other documentation
• Communicating the results of the consultation

The following codes should be used for a follow-up inpatient telemedicine consultation:

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The ins and outs of telehealth coding

Medical coding is finicky in its own right, and when telehealth is added to the mix, the process becomes even more complex.

In order to be properly reimbursed, there are specific requirements that must be met for care provided via telehealth. 

Here is what anesthesiologists — and physicians in general — need to know about the rules and regulations of telehealth coding, according to an April 15 post by medical revenue cycle management group Coronis Health.

Medicare Part B pays for services that a physician or practitioner provides "via 2-way, interactive technology," according to a February 2024 Medicare Learning Network article cited by Coronis. Coronis notes that telehealth substitutes for an in-person visit and generally involves two-way, HIPAA-compliant audio-visual interactive technology that permits communication between the physician and patient; however, Section 4113 of the Consolidated Appropriations Act permits audio-only telehealth for some non-behavioral health services through December 31.

In 2023, physicians were required to report the place of service the patient would have been seen in if the visit was in person — for example, either at an office or a facility — with the 95 modifier, which indicated telehealth services. However, Medicare changed the requirements at the beginning of this year. 

For telehealth services, it is no longer necessary to report the place of services or to use the 95 modifier. Instead, claims must use one of two codes:

• POS 02: Telehealth provided in other than the patient's home.
• POS 10: Telehealth for services when a patient is in their home.

However, there is one exception: when the patient is in their home and the provider is in the hospital, in which case the hospital place of service code is used along with the 95 modifier, according to the group.

In review, there are four essential pieces of information that need to be documented for accurate telehealth coding:

• The patient's agreement to a telehealth visit. 
• The patient’s location during the visit.
• The provider's location during the visit.
• The platform being used, with indication of whether the visit was via audio-visual or audio only

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The plots show estimates and 95% CIs from ordinary least squares linear regression models adjusting for daily visit volume, and physician and calendar day fixed effects. N = 67 894 for all outcomes except next-day documentation time (n = 47 297). Estimates and 95% CIs for 100% telemedicine days do not reach statistical significance and exhibit wide variation due to relatively few observations; thus, they were omitted for readability.

a Reference category is zero telemedicine visits.

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Apathy NC , Zabala G , Gomes K , Spaar P , Krevat SA , Ratwani RM. Telemedicine and In-Person Visit Modality Mix and Electronic Health Record Use in Primary Care. JAMA Netw Open. 2024;7(4):e248060. doi:10.1001/jamanetworkopen.2024.8060

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Telemedicine and In-Person Visit Modality Mix and Electronic Health Record Use in Primary Care

• 1 National Center for Human Factors in Healthcare, MedStar Health Research Institute, Washington, DC
• 2 Department of Emergency Medicine, Georgetown University School of Medicine, Washington, DC
• 3 Department of General Internal Medicine, Georgetown University School of Medicine, Washington, DC

Telemedicine use increased substantially during and after the COVID-19 pandemic 1 and has the potential to provide low-acuity medical services at lower costs. 2 However, telemedicine also levies new costs on clinicians. 3 Telemedicine requires shifting care delivery workflows, as it rarely includes clinical support staff but can involve levels of patient complexity similar to in-person visits. 4 , 5 This may increase administrative and electronic health record (EHR) burden for clinicians and increase cognitive costs as clinicians switch modalities. In a recent study, 6 greater weekly telemedicine visit share was associated with increased EHR time, including after-hours time, mostly spent in documentation. Our study aimed to address 2 gaps: first, whether day-to-day changes in telemedicine share demonstrate a similar association with EHR time; and second, what changes occur in domains of EHR use not examined in previous studies (eg, medical record review, orders).

This cross-sectional study combined visit modality data with EHR active use data capturing time spent by primary care physicians (PCPs) in the Cerner EHR system from December 2021 through June 2023 at MedStar Health, a large multispecialty health system in the mid-Atlantic region. We calculated PCPs’ daily telemedicine share as the percentage of the day’s visits conducted via telemedicine and categorized this variable into 5 levels. Because we used deidentified data, this study was deemed exempt and not human participant research by the Georgetown University–MedStar Health Institutional Review Board; we followed the STROBE reporting guideline.

Telemedicine visits were identified via registration and scheduling records. We analyzed 5 measures of active EHR time for each PCP-day: total EHR time, documentation time, medical record review time, order time, and next-day documentation time (only for PCP-days with a consecutive qualifying PCP-day). We calculated descriptive statistics and ran ordinary least squares linear regression models, adjusting for visit volume and physician and calendar-day fixed effects. These models estimate the marginal within-clinician association between each telemedicine share level and our outcomes relative to zero-telemedicine days while adjusting for common temporal trends. We used R statistical software, version 3.6.3 (R Project for Statistical Computing) (tidyverse, fixest packages) for analyses, using 2-tailed hypothesis tests (α = .05).

The study included 316 PCPs observed across 67 894 PCP-day observations distributed across 5 daily telemedicine share categories (zero daily telemedicine share, 44.7% of all PCP-days; ≤10% share, 17.2%; 11%-25% share, 24.8%; 26%-99% share, 11.1%; and 100% share, 2.2%); mean (SD) overall visit volume, 13.9 (7.2) visits/d ( Table ). All outcomes demonstrated statistically significant differences across telemedicine share levels. The mean (SD) documentation time for PCPs was 71.3 (54.3) minutes on zero-telemedicine days and 87.1 (50.0) minutes on days with up to 10% telemedicine visits. In regression analyses, days with a mix of visit modalities were associated with significantly greater time for EHR, documentation, and medical record review ( Figure ). Compared with zero-telemedicine days, 26% to 99% telemedicine days were associated with 14.8 (95% CI, 7.6-22.0) more minutes of active EHR time (5.6% increase, P  < .001), 4.7 (95% CI, 1.2-8.3) additional documentation minutes (6.0% increase, P  = .01), and 5.5 (95% CI, 2.8-8.2) additional medical record review minutes (6.2% increase, P  < .001). Telemedicine share resulted in a negligible increase in order time and had no association with next-day documentation time ( Figure ).

This cross-sectional study found that, during clinic days with both telemedicine and in-person visits, PCPs had 5.6% to 6.2% more EHR-based work. This work did not spill over into next-day documentation, suggesting that PCPs absorbed added time into their workload on mixed-modality days. However, we found that fully telemedicine days were not associated with EHR-based work, contrary to previous findings. 6 We attribute this difference to the small sample of fully telemedicine PCP-days in our study in comparison with prior work 6 (2.2% vs 16.5% of physician-weeks) as well as higher mean visit volume (13.9 visits/d vs 20 visits/wk) ( Table ). Greater EHR time may be due to increased multitasking during telemedicine visits, as PCPs simultaneously engage with patients and the EHR during telemedicine visits in ways that are not possible in person. This multitasking may feel more efficient and therefore may not register as “burdensome”; further research should explore whether added EHR time associated with mixed-modality days further burdens PCPs. Limitations of our study include our setting of a single health system, lack of information on visit and patient characteristics and on clinicians’ experience with telehealth tools, and lack of clinical outcomes.

Accepted for Publication: January 22, 2024.

Published: April 24, 2024. doi:10.1001/jamanetworkopen.2024.8060

Open Access: This is an open access article distributed under the terms of the CC-BY License . © 2024 Apathy NC et al. JAMA Network Open .

Corresponding Author: Nate C. Apathy, PhD, National Center for Human Factors in Healthcare, MedStar Health Research Institute, 3007 Tilden St NW, Washington, DC 20008 ( [email protected] ).

Author Contributions: Dr Apathy had full access to all of the data in the study and takes responsibility for the integrity of the data and the accuracy of the data analysis.

Concept and design: Apathy, Gomes, Ratwani.

Acquisition, analysis, or interpretation of data: Apathy, Zabala, Spaar, Krevat.

Drafting of the manuscript: Apathy.

Critical review of the manuscript for important intellectual content: Zabala, Gomes, Spaar, Krevat, Ratwani.

Statistical analysis: Apathy.

Obtained funding: Gomes, Ratwani.

Administrative, technical, or material support: Zabala, Gomes.

Conflict of Interest Disclosures: Dr Apathy reported receiving grants from the Agency for Healthcare Research and Quality (AHRQ) during the conduct of the study; personal fees from the Office of the National Coordinator for Health IT, the American Medical Association, Yale University, and the University of California–San Francisco outside the submitted work. Mr Zabala and Drs Gomes, Krevat, and Ratwani reported receiving grants from AHRQ during the conduct of the study. No other disclosures were reported.

Data Sharing Statement: See the Supplement .

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The Joint Commission Launches Telehealth Accreditation

New program provides structures and processes to help healthcare organizations deliver safe, high-quality care remotely Tuesday, April 23, 2024

Media Contact:

Maureen Lyons Corporate Communications (630) 792-5171

The Joint Commission today announced it is launching a new Telehealth Accreditation Program  for eligible hospitals, ambulatory and behavioral healthcare organizations, effective July 1, 2024. This accreditation program provides updated, streamlined standards to provide organizations offering telehealth services with the structures and processes necessary to help deliver safe, high-quality care using a telehealth platform.

The Telehealth Accreditation Program was developed for healthcare organizations that exclusively provide care, treatment and services via telehealth. Hospitals and other healthcare organizations that have written agreements in place to provide care, treatment and services via telehealth to another organization’s patients have the option to apply for the new accreditation.

The Telehealth Accreditation Program’s requirements contain many of the standards similar to other Joint Commission accreditation programs, such as requirements for information management, leadership, medication management, patient identification, documentation, and credentialing and privileging. Requirements specific to the new accreditation program include:

• Streamlined emergency management requirements to address providing care and clinical support remotely rather than in a physical building.
• New standards for telehealth provider education and patient education about the use of telehealth platforms and devices.
• New standards chapter focused on telehealth equipment, devices and connectivity.

Additionally, the program’s standards may be filtered based on the telehealth modality or service provided.

“The use of telehealth in the United States increased 154% during early stages of the COVID-19 pandemic and stabilized at levels 38 times higher than levels in 2019. As telehealth continues to evolve, it was imperative to create a new accreditation program to provide a framework to support the integrity of patient safety regardless of the care setting,” says Jonathan B. Perlin, MD, PhD, president and chief executive officer, The Joint Commission enterprise. “Our new Telehealth Accreditation Program helps organizations standardize care and reduce risk so that all patients, including those obtaining services remotely, receive the safest, highest-quality care with outcomes consistent with traditional settings.”

The Telehealth Accreditation Program will replace the current telehealth and technology-based accreditation products in The Joint Commission’s Ambulatory Health Care and Behavioral Health Care and Human Services Accreditation Programs for organizations that meet the eligibility criteria.

To learn more about the Telehealth Accreditation Program, please visit  The Joint Commission website .

About The Joint Commission

Founded in 1951, The Joint Commission  seeks to continuously improve healthcare for the public, in collaboration with other stakeholders, by evaluating healthcare organizations and inspiring them to excel in providing safe and effective care of the highest quality and value. The Joint Commission accredits and certifies more than 22,000 healthcare organizations and programs in the United States. An independent, nonprofit organization, The Joint Commission is the nation’s oldest and largest standards-setting and accrediting body in healthcare. Learn more about The Joint Commission at www.jointcommission.org .

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