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This is an update of the blog Expansion of Telehealth for Medicare Patients during the COVID-19 Emergency – Key Points

With telehealth widely accepted as the gold standard for care to fight COVID-19, the government and payers are adapting their guidelines and policies to meet the new and complex needs of patients and providers. Staying up-to-date with regulatory changes made during the current Public Health Emergency (PHE), as every medical billing company knows, is critical for accurate telehealth billing and coding. In fact, on April 4, 2020, Medicare changed its guidance for billing for professional telehealth distant site services issued on March 31, 2020. Here are the key updates:

Medicare defines telehealth as two-way telecommunications using interactive audio and video that permit real time communication between medical providers and patients. CMS rules for billing professional claims for all telehealth services with dates of services on or after March 1, 2020, and for the duration of the PHE are as follows:

    • Place of Service (POS) and Modifier 95

  • Bill with Place of Service (POS) same as what it would have been if the service been furnished in-person.
  • The place of service code would be the location the patient encounter would have occurred, except for the outbreak.
  • If the visit had been in the clinic, POS 11 should be used.
  • If the visit had taken place in an outpatient hospital, POS 19 (Off-Campus Outpatient Hospital) or 22 (On-Campus Outpatient Hospital) should be used as appropriate.
  • A house call doctor that typically sees the patient at their home should bill with POS 12 and use the house visit codes.
  • A physician’s home has to be enrolled when the physician performs telehealth from a home office. The same place of service should be used that the physician would be using should be used if it weren’t for the COVID-19 crisis, i.e., 11 for office can be used as this is where the physician would have before the pandemic.
  • Modifier 95 should be appended, indicating that the service was rendered via a synchronous or real-time audiovisual interaction between a patient and a provider, in which the provider at a distant site provides healthcare services for a patient at a different location.
  • POS 02 should not be used in telehealth. If any service is reported with POS 02 (“Telehealth”) it will be paid at the facility rate under the Medicare physician fee schedule, which is likely to be lower than the corresponding non-facility rate.
    • Medicare Part B – Documentation of E&M Visits via Telehealth

There are new rules for documenting Medicare Part B patient visits done via telehealth:

    • When choosing the code for a telehealth encounter, the level of service will be determined either based on medical decision making (MDM) or time, though the category of EM code (new patient, established patient, subsequent hospital care, etc.) remains unchanged.
    • “Time” is defined as all the time associated with the E/M on the day of the encounter. The current typical times associated with office/outpatient E/M codes in CPT are what should be met for the purposes of level selection (
    • Time can be used even if counselling takes place.
    • CMS has retained the current definition of MDM.
    • Neither history nor exam will impact code assignment. All requirements have been removed regarding documentation of history and/or physical exam in the medical record for office/outpatient E/M visit (CPT codes 99201-99215) furnished via Medicare telehealth.
    • Telephone Calls

      CMS allows telephone calls and has finalized payment for telephone codes 99441 to 994443 for physicians, and 98966 to 98968 for nonphysicians during the COVID-19 pandemic. Though the code description states that apply only to established patients, CMS is permitting the use of telephone codes for new patients as well.

    • CS Modifier on Claims relating to COVID-19 Testing Services

      Through the PHE, physicians, other providers, and suppliers that bill Medicare for Part B service should use the CS modifier on claims for COVID-19 testing-related services. Using the CS modifier will identify the service as subject to the cost-sharing wavier for COVID-19 lab tests.

    • Additional Regulatory Relief for Family Physicians:

      • For Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), the services included in Virtual Communication Services (code G0071) have been expanded to cover the services reflected in CPT codes 99421-99423 (Online digital E/M services).
      • Physicians will not be subject to sanctions for routinely reducing or waiving cost sharing for a broad category of non-face-to-face services such as telehealth visits, virtual check-in services, e-visits, monthly remote care management, and monthly remote patient monitoring.

While the above updates are for Medicare services, private health insurance companies may have their own rules with regards to place of service and modifiers. Additional CMS actions in response to COVID-19 can be expected in the coming days. US based medical billing and coding companies keep track of the updates of government and private payers so that they can help providers submit accurate claims for reimbursement.

Rajeev Rajagopal

Rajeev Rajagopal, the President of OSI, has a wealth of experience as a healthcare business consultant in the United States. He has a keen understanding of current medical billing and coding standards.

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