The pandemic forced doctors and other practitioners to adopt telehealth to continue helping patients without exposure to the risks of COVID-19. As a result, health care providers have also had to figure out proper billing for telehealth activities.

In this article, we explain important concepts related to billing telehealth for your practice. We also shed light on some of the ways our company can keep your billing procedures current on guidance from CMS and other organizations for improved reimbursement percentages.

List of Telehealth Services

Concepts like telehealth and telemedicine exist because the technologies at our disposal allow for more efficient exchanges of information between physicians and patients. The terms refer to any electronic communication for the purpose of improving a patient’s health. This includes emails, phone calls, website portals, and video calls. Telehealth services generally come in three forms:

  • Medicare telehealth visits
  • Virtual check-ins
  • E-visits

Billing for Telehealth Services During COVID-19

Many states, executive offices, insurance companies, and related agencies expanded the scope of healthcare billing to incorporate more telehealth services due to COVID-19. For these entities, telehealth billing procedures are uncharted territory, which means guidance and best practices tend to change with little notice. To address this gap, our billing experts regularly monitor updates from public and private health care payers (i.e., CMS and private insurance) related to reimbursement requirements.

Medicare Payment Policies During COVID-19

Through federal legislation and other guidance from CMS and the CDC, new telehealth payment policies for Medicare beneficiaries are as follows:

  • No more restrictions for telehealth services to beneficiaries in rural areas
  • Beneficiaries can receive services both at-home and through their smartphone
  • Physicians can provide telehealth to patients without a pre-existing relationship (i.e., not established patients)

Physicians can also seek expanded Medicare advance payment options to cover the rising costs of equipment and technology to meet the safety needs of COVID-19.

Billing and Coding Medicare Fee-for-Service Claims

Medicare’s fee-for-service (FFS) compliance programs exist to educate and monitor providers and their billing departments on proper EMR and coding procedures. This is to ensure reimbursement for Medicare approved healthcare services. Our billing specialists work as a bridge between CMS compliance and health care providers for quality Medicare billing practices.

Billing Medicare as a Safety-Net Provider

Rural health clinics (RHCs) and federally qualified health centers (FQHCs) can also provide Medicare services through telehealth. Key information you should know include the following:

  • The current reimbursement rate for RHCs and FQHCs is $92.03, retroactive to January 27, 2020.
  • As of March 6, 2020, a patient’s home can be considered as the originating site.
  • Online digital evaluation and management are not Medicare telehealth services, but one can still seek reimbursement at a different rate under coverage for virtual communication services.

State Medicaid Telehealth Coverage

State Medicaid telehealth coverage will vary from state to state. Physicians and health care providers will need to consult with their local government agencies (e.g., health departments) for information on the availability of Medicaid coverage for telehealth.

Private Insurance Coverage for Telehealth

Look for information from private insurance groups on how they handle telehealth reimbursement and payment processing. Every insurer will have its own guidelines and protocols.

Expansion of Telehealth with the 1135 Waiver

CMS expanded telehealth coverage through the 1135 waiver and the Coronavirus Preparedness and Response Supplemental Appropriations Act.

Types of Virtual Services

Telehealth includes three types of virtual services.

Medicare Telehealth Visits

Any visit between a patient and provider that uses telecommunication systems.

Virtual Check-ins

A brief online conversation (5 to 10 minutes) between a patient and provider to assess the need for additional visits or follow-up service.


Any communication between patient and provider through an online patient portal (not necessarily real-time).

Coding for Telehealth and Other Outpatient Remote Services

Strict coding protocols are followed for the uniform delivery of telehealth services. Here are some of them.

Telehealth Visits

The appropriate CPT code for billing telehealth services will generally depend on the nature of the patient’s medical condition, along with service logistics (e.g., duration, telecommunication methods, etc.).

Telephone E/M Services

Providers can bill audio-only services under the following codes, depending on the duration:

  • 99441: 5-10 minutes of medical conversation
  • 99442: 11-20 minutes of medical conversation
  • 99443: 21-30 minutes of medical conversation

Digital E/M Services

Digital evaluation and management codes also vary by length for established patients, as follows:

  • 99421: 5-10 minutes
  • 99422: 11-20 minutes
  • 99423: 21 or more minutes

Virtual Check-Ins

  • HCPCS code G2012: for brief communications (5-10 minutes)
  • HCPCS code G2010: review of recorded video or images and any follow-up within 24 hours

Remote Patient Monitoring

There are codes for the different stages of the collection and analysis of a patient’s physiological data through transmitting devices (i.e., blood-pressure, glucose, etc.):

  • 99453
  • 99454
  • 99457
  • 99458

For Observation, Inpatient, and Emergency Department Telehealth Services

These refer to the codes for different telehealth services, from initial consultations through to eventual discharge.

Diagnosis Coding

Different codes exist when making a diagnosis through a telecommunication system, as opposed to physical evaluations.

Patient Cost-Sharing

Physicians can waive or reduce the cost-sharing requirements for Medicare beneficiaries. Additionally, some commercial payers have waived cost-sharing requirements for telemedicine because of COVID-19.

Payer Resources

Continue monitoring websites and other communications from private payers about how they are handling COVID-19 and telehealth services through the end of 2021 and into 2022.

Obtaining Consent for a Sterilization Procedure Via Telehealth

Physicians of women covered through public family-planning programs can apply for and receive consent for sterilization service reimbursements through HHS Form 687.

Policy Changes for Prescribing Controlled Substances Via Telehealth

During the public health emergency, policy changes from the DEA and other agencies now allow for providers to prescribe controlled substances through telehealth without the need for in-person medical evaluations.

Frequently Asked Telehealth Questions

Below are some quick answers to common questions about billing for telehealth services.

1. Are telemedicine visits paid the same as in-person visits?

Generally, yes. Telemedicine visits involve the same types of service as in-person visits. The only differences would be the physical locations of the patient and provider.

2. If cost-sharing is waived, will my payment be reduced?

CMS and Medicare will not reduce reimbursement payments if providers choose to waive cost-sharing.

3. When do the cost-sharing waivers expire?

The government has yet to determine the exact date for cost-sharing waivers to expire, but it will generally end at the conclusion of the public health emergency.

4. What do I do if cost-sharing wasn’t applied appropriately, or I wasn’t paid at parity?

You can report technical issues or other concerns to the CMS or any related state agency for discrepancies with cost-sharing application or parity payment.

5. Are there cost-sharing waivers for treatment related to COVID-19?

Most insurers have either ceased cost-sharing waivers or have started phasing out cost-sharing waivers for COVID-19 treatment.

Schedule a meeting with our billing team for more information on how we can help your office with billing telehealth services and other medical coding needs.

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