telephone visit cpt code place of service

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Billing and coding Medicare Fee-for-Service claims

Read the latest guidance on billing and coding Medicare Fee-for-Service (FFS) telehealth claims.

On this page:

Telehealth codes covered by medicare, coding claims, common telehealth billing mistakes, more information about ffs billing.

Medicare added over one hundred CPT and HCPCS codes to the list of telehealth services .

Telephone visits and audio-only telehealth

Medicare is temporarily waiving the audio-video requirement for many telehealth services. Codes that have audio-only waivers are noted in the list of telehealth services .

Place of Service codes

When billing telehealth claims, it is important to understand the place of service (POS) codes as it affects reimbursement.

The POS code (PDF) explains where the provider and patient are located during the telehealth encounter. There are currently two POS codes:

• POS 02: Telehealth provided other than in patient's home. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
• POS 10: Telehealth provided in patient's home. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.

Avoiding mistakes in the reimbursement process can help implementing telehealth into your practice a smoother experience.

Incorrect billing codes

More than 100 telehealth services are covered under Medicare. However, some CPT and HCPCS codes are only covered temporarily.

Using the wrong code can delay your reimbursement. This can happen for a variety of reasons, such as a misunderstanding of what code applies to what service or input error.

Stay up to date on the latest Medicare billing codes  for telehealth to keep your practice running smoothly.

Documentation

Post-visit documentation must be as thorough as possible to ensure prompt reimbursement.

While there are many similarities between documenting in-person visits and telehealth visits, there are some key factors to keep in mind.

Patient consent

Make a note of whether the patient gave you verbal or written consent to conduct a virtual appointment.

Code categories

Telephone codes are required for audio-only appointments, while office codes are for audio and video visits.

Time of visit

A common mistake made by health care providers is billing time a patient spent with clinical staff. Providers should only bill for the time that they spent with the patient.

Store-and-forward

Many states require telehealth services to be delivered in “real-time”, which means that store-and-forward activities are unlikely to be reimbursed. You can find information about store-and-forward rules in your state here  .

Originating sites and distant sites

Learn about eligible sites as well as telehealth policies specific to Federally Qualified Health Centers and Rural Health Clinics.

If you are looking for detailed guidance on what is covered and how to bill Medicare FFS claims, see:

• Billing for Telehealth Encounters: An Introductory Guide on Fee-for-Service  (PDF) – from the National Policy Center - Center for Connected Health Policy

Medicaid and Medicare billing for asynchronous telehealth

Learn how to bill for asynchronous telehealth, often called “store and forward".

Billing Medicare as a safety-net provider

Medicare billing and coding guidelines on telehealth for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).

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Telephone Visits Billing, Coding and Regulations Information

Some patients may not be able to have video visits because they don’t have access to interactive audio-video technology, they may not be facile with technology, or they may just prefer not to use video technology. Practices can use audio-only telephone calls to provide care to their patients if video visits are not possible. 

• For the duration of the public health emergency, CMS and some private payers are allowing audio-only telephone calls to be billed in the same way as in-person visits and these visits will be paid in equivalent amounts as E&M codes 99212-99214. This change is effective April 30, 2020, and is retroactive to March 1, 2020. The following criteria apply to Medicare visits during the emergency. 
• Can be used for new or established patients. 
• Document verbal consent and why in-person or audio-video encounter was not possible 

Billing and Coding 

• Use modifier -93 for the reporting of medical services that are provided via real-time interaction between the physician or other qualified health care professional (QHP) and a patient through audio-only technology. The totality of the communication of information exchanged during the course of the service must be of an amount and nature that is sufficient to meet the key components and/or requirements of the same service when rendered via a face-to-face interaction. This modifier is effective January 1, 2022. 
• Use the normal Place of Service, e.g. POS = 11 for private practice. 
• ​99441​ - Medical discussion of 5 to 10 minute duration
• 99442​ - Medical discussion of 11 to 20 minute duration
• 99443​ - Medical discussion of 21 to 30 minute duration

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September 13, 2024

Coding Telehealth Visits: Place of Service

Information in this article was updated July 2023, based on the 2024 Proposed Physician Fee Schedule Rule.

Coding telehealth visits changes faster than the weather here in New England. The resources on the site relate to Medicare policy and CPT codes and rules. Unfortunately, they don’t address individual commercial payer policies.

• There are two new POS codes for coding telehealth visits, but don’t start using them for Medicare.
• Place of service codes determine if the encounter is paid at the facility or non-facility rate. The non-facility rate is a higher rate of reimbursemnet.
• Congress passed a law 12/20/2020 that allows behavioral health services to continue to be billed via telehealth after the end of the public health emergency.
• The Consolidated Appropriates Act, 2023 extended certain telehealth flexibilities through Dec. 31, 2024. These are described in another article on CodingIntel.

CMS is proposing that beginning in CY 024, claims submitted with POS 10 will be paid at the higher, non-facility rate.

Beginning January 1, 2024, claims submitted with POS 02 will be pad at the lower, facility rate.

POS 02 : Telehealth Provided Other than in Patient’s Home

Description: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.  (Effective January 1, 2017) (Description change effective January 1, 2022, and applicable for Medicare April 1, 2022.)

POS 10: Telehealth Provided in Patient’s Home

Description: The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology. (This code is effective January 1, 2022, and available to Medicare April 1, 2022.)

See CMS’s MedLearn Matters article describing the new POS code. It seems to indicate we shouldn’t use it!  Here is what they say:

“ Medicare hasn’t identified a need for new POS code 10. Our MACs will instruct their providers to continue to use the Medicare billing instructions for Telehealth claims in Pub. 100-04, Medicare Claims Processing Manual, Chapter 12, Section 190 .”

This policy is confirmed in the 2023  Physician Fee Schedule Final Rule.

“As such, we are finalizing that we will continue to allow for payment be made for Medicare telehealth services at the place of service for telehealth services that ordinarily would have been paid under the PFS, if the services were furnished in-person, through the latter of the end of the of CY 2023 or the end of the calendar year in which the PHE ends. For those services furnished in a facility as an originating site, POS 02 may be used, and the corresponding facility fee can be billed, per pre-PHE policy, beginning the 152nd day after the end of the PHE.” page 197

Continue to use the place of service in which the service would have been provided until Dec. 31, 2024.

What about a patient in their car? 

From the 2023 Final Rule, p. 193. “ We remind readers that we defined “home” in our CY 2022 PFS final rule (86 FR 65059)to include, as: “both in general and for this purpose, a beneficiary’s home can include temporary lodging, such as hotels and homeless shelters. We also clarified that for circumstances where the patient, for privacy or other personal reasons, chooses to travel a short distance from the exact home location during a telehealth service, the service is still considered to be furnished ‘in the home of an individual’ for purposes of section 1834(m)(4)(C)(ii)(X) of the Act.”

Use POS 10 in this situation.

POS “10” – Telehealth Provided in Patient’s Home

One MAC, NGS posted a question about this, which is linked below.

https://www.ngsmedicare.com/web/ngs/news-article-details?lob=96664&state=97224&rgion=93623&selectedArticleId=3794814

And, here is a link to the Family Practice Management journal article that describes the policies of two other payers.

Coding telehealth visits

• Telemedicine and COVID-19 FAQ
• Telemedicine in RHCs and FQHCs
• Is it or isn’t it a telehealth service
• Telemedicine | Webinar
• Payment for telephone calls
• Overview of Medicare telehealth services
• Interprofessional Internet Consultations
• CPT® codes (99421-99423) – and payment for – online digital evaluation and management (E/M) services
• Virtual communication: two new HCPCS codes G2010 and G2012
• Should we begin using the new CPT modifier -93
• Modifier 95
• Modifier CS
• Medicare changes telehealth rules, again

Telehealth source documents you can download

• CMS list of telehealth
• AMA coding advice
• CMS interim rule – March 30, 2020
• CMS interim rule – April 30, 2020
• CMS enrollment COVID-19PEHotline
• Aledade guide to getting started with telehealth

Get more tips and coding insights from coding expert Betsy Nicoletti.

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Last revised June 27, 2024 - Betsy Nicoletti Tags: telehealth

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Our mission is to provide up-to-date, simplified, citation driven resources that empower our members to gain confidence and authority in their coding role.

In 1988, CodingIntel.com founder Betsy Nicoletti started a Medical Services Organization for a rural hospital, supporting physician practice. She has been a self-employed consultant since 1998. She estimates that in the last 20 years her audience members number over 28,400 at in person events and webinars. She has had 2,500 meetings with clinical providers and reviewed over 43,000 medical notes. She knows what questions need answers and developed this resource to answer those questions.

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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. 

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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