Telehealth Billing & Coding Requirements

Telehealth Billing

Keep up with today’s requirements for telehealth billing and coding in our latest Pivot Point Perspective.

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Under the Coronavirus Preparedness and Response Supplemental Appropriations Act and Section 1135 waiver authority, the Centers for Medicare & Medicaid Services (CMS) broadened access to Medicare telehealth services so beneficiaries can get a wider range of services from their doctors and other clinicians without traveling to a healthcare facility.

Under this Section 1135 waiver expansion, physicians, nurse practitioners, psychologists and licensed clinical social workers and others can offer a special set of telehealth services including evaluation and management visits (common of e-Visits), mental health counseling and preventive health screenings.

Additionally, beneficiaries can get telehealth services in any healthcare facility — including a physician’s office, hospital, nursing home or rural health clinic — as well as from their homes.

How to Bill Telehealth Visits

Medicare telehealth services are generally billed as if the service is furnished in person. The claim should reflect the designated Place of Service (POS) code 02-Telehealth to indicate the billed service was furnished as a professional telehealth service from a distant site.

Providers will need to apply for any waiver that wasn’t included in the blanket waivers approved as part of the COVID-19 pandemic if they wish to seek relief in additional areas. The request for waiver should be emailed to the CMS Regional

Office in their service area. Providers should also check their specific state requirements for full details based on where they are located to understand how they should be handling telehealth for Medicaid patients.

In addition to the direct billing issues many states have waived licensure requirements to allow providers to

virtually treat patients across state lines. Providers should check the Federation of State Medical Boards (FSMB) for the most up to date list as things continue to evolve.

Types of Virtual Services That Can be Offered

There are three main types of virtual services physicians and other professionals can provide to Medicare beneficiaries.


Medicare patients may use telecommunication technology for office, hospital visits and other services that generally occur in-person.

  • The provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home.
  • The requirement that the patient have a prior established relationship with a particular practitioner will not be subject to audit for any claims submitted during this public health emergency.
  • These visits are considered the same as in-person visits and are paid at the same rate as regular, in person visits.


In all areas (not just rural), established Medicare patients in their home may have a brief communication service in their home with practitioners via a number of communication technology modalities including synchronous discussion over a telephone or exchange of information through video or image.

  • Regulations state virtual services should be initiated by the patient; however, practitioners may need to educate beneficiaries on the availability of the service prior to patient initiation.
  • Medicare pays for “virtual check-ins” (or brief communication technology-based service) for patients to communicate with their doctors and avoid unnecessary trips to the doctor’s office.
  • Virtual check-ins are for patients with an established (or existing) relationship with a physician or certain practitioners where the communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours (or soonest appointment available).
  • Visits should be coded with HCPCS code G2012 (brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion).
  • If the patient submits some type of video or image HCPCS code, G2010 (remote evaluation of recorded video and / or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment) should be used.


In all types of locations including the patient’s home, and in all areas (not just rural), established Medicare patients may have non-face-to-face, patient-initiated communications with their doctors without going to the doctor’s office by using online patient portals.

  • Services can only be reported when the billing practice has an established relationship with the patient.
  • For these e-Visits, the patient must generate the initial inquiry and communications can occur over a 7-day period.
  • Services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable.
  • Patient must verbally consent to receive virtual check-in services.
  • Medicare Part B also pays for E-visits or patient-initiated online evaluation and management conducted via a patient portal.
  • Practitioners who may independently bill Medicare for evaluation and management visits (for instance, physicians and nurse practitioners) can bill the following codes:
    • 99421: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
    • 99422: Online digital evaluation and management service, for an established patient, for up to 7 days cumulative time during the 7 days; 11– 20 minutes
    • 99423: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes

Questions to ask your organization.

  • What will our standard language be for justification of telehealth service for documentation purposes?
  • Will our organization permit the use of non-HIPAA compliant technologies such as FaceTime or Skype?
  • Are my consent forms inclusive of services provided via telehealth?
  • How do we rapidly educate our providers as well as billing and coding staff about the changes?

The information provided here is current as of 3/30/20. Please contact our Telehealth specialists at 800-318-9681 or for updates or questions.

See more of our Rapid Response COVID-19 resources and solutions.

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