Managing Patients Remotely: Billing for Digital and Telehealth Services

Updated as of September 2023

Both public and private health insurers have taken steps to increase access to telehealth services even after the end of COVID-19 public health emergency (PHE). For a detailed summary on the major telehealth policy changes for Medicare, Medicaid, and commercial payers, please reference our Telehealth page. Below you will information on how to code and bill for the remote management of patients. We will update this resource as policies change.

Major Medicare Telehealth Policy Changes Post-Public Health Emergency

Many commercial payers are also following Medicare guidelines for telehealth amid the end of public health emergency:

Telehealth visits will be covered for all traditional Medicare beneficiaries regardless of geographic location or originating site
You are not required to have a pre-existing relationship with a patient to provide a telehealth visit
You can bill audio-video or audio-only telehealth visits as if they were provided in-person
Physician office telehealth visit payment rates will remain the same as in-person
You can provide telehealth services if you are eligible to bill Medicare for services

Coding for Telehealth and Other Outpatient Remote Services

*Note: some payers are reimbursing for audio-only evaluation and management services using these codes

Telehealth Visits

Synchronous audio/visual evaluation and management visit:

99202-99205: Office/outpatient E/M visit, new patient
99211-99215: Office/outpatient E/M visit, established patient
G0425-G0427: Consultations, emergency department or initial inpatient (Medicare only)
G0406-G0408: Follow-up inpatient telehealth consultations for patients in hospitals or SNFs (Medicare only)

Attach the following modifiers to these codes as required to indicate this was a telehealth visit:

Modifier 95 – Required by most commercial payers, can use on an interim basis for Medicare telehealth billing*
Note: Medicare typically requires the Place of Service code “02” and “10” for telehealth services; however, practitioners billing Medicare telehealth services during the end of COVID-19 public health emergency should use the same place of service code they typically use when billing for in-person services

Telephone E/M Services

Telephone or audio-only evaluation and management services for new and established patients cannot originate from a related E/M service provided within the previous 7 days nor lead to an E/M service or procedure within the next 24 hours or soonest available appointment. Covered but not separately payable. *

99441: 5-10 minutes
99442: 11-20 minutes
99443: 21-30 minutes

Digital E/M Services

Online digital E/M services for an established patient for a period of up to 7 days, cumulative time during the 7 days. These codes can be billed once a week and cannot be billed within a 7-day period of a separately reported E/M service or during a global period of a surgical procedure, unless the patient is initiating an online inquiry for a new problem not addressed in the separately reported E/M visit. These services must be initiated by the patient (e.g., patient portal, e-mail). Medicare may not pay for these as they are not on the list of Medicare’s covered services.

Physicians report:

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

Qualified non-physician professionals report:

98970 or G2061: 5-10 minutes
98971 or G2062: 11-20 minutes
98972 or G2063: 21 or more minutes

For Medicare, non-physicians report: G2061-G2063

Virtual Check-Ins

The following cannot originate 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. Only covered for Medicare beneficiaries

G2012 – Brief communication (5-10 minutes) technology-based service, established
G2010 – Remote evaluation of recorded video and/or images submitted, established, including interpretation and follow-up within 24 business hours

Remote Patient Monitoring

99453: Initial set-up and patient education on the use of monitoring equipment
99454: Initial collection, transmission and report/summary services to the clinician managing the patient
99457: Remote physiologic monitoring treatment management services, clinician time in a calendar month requiring interactive communication with the patient or caregiver, first 20 minutes in the month
99458: Each additional 20 minutes (list in addition to code from primary procedure)
99473: Self-measured blood pressure using a device validated for clinical accuracy; patient education/training and device calibration. Report once per device.
99474: Separate self-measurements of two readings one minute apart, twice daily over a 30-day period (minimum of 12 readings), collection of data reported by the patient or caregiver to the physician or QHP, with report of average blood pressures and subsequent communication of a treatment plan to the patient
99091: Collection and interpretation of physiologic data (e.g., blood pressure) digitally stored and/or transmitted by the patient to the physician or QHP, requiring a minimum of 30 minutes of time, each 30 days

Diagnosis Coding

Appropriate diagnosis coding will depend upon the condition being assessed remotely. Be sure to support and link your procedure code to a diagnosis that supports the medical necessity for performing the service.

Patient Cost-Sharing

Medicare: Physicians have the option of waiving or reducing patient cost-sharing requirements for Medicare beneficiaries. Should a physician choose to waive or reduce cost-sharing requirements, Medicare will not increase reimbursement rates for physicians to cover this cost.
Commercial payers: Some may impose cost-sharing requirements for telehealth services amid post PHE. Check with your payers to verify their telehealth cost-sharing requirements.

Payer Resources

Private payers continue to update their policies even after the COVID-19 PHE. Many have extended their COVID-19 policies through the end of the year. To check each payer’s most updated policy changes in relation to the billing and coding for telehealth and COVID-19, please visit the payer’s website.
When well-woman visits are provided half via telehealth and half in-person, some major private payers will pay for a telehealth E/M visit and an in-person preventive medicine visit, while others will only pay for one visit. Check with your payers on their policy.

Obtaining Consent for a Sterilization Procedure Via Telehealth

For women covered under publicly-funded family planning programs, including Medicaid, physicians may conduct contraceptive counseling, including counseling for a sterilization procedure, via telehealth. HHS Form 687 (and attendant state forms) require a patient signature verifying their consent for sterilization. During a telehealth visit, practitioners may be able to facilitate the signing of HHS Form 687 using an electronic signature platform such as DocuSign, if the patient is able to access the form on this platform. This process will require a computer, smartphone, or tablet.

Suggested coding for this encounter: reports an outpatient E/M code and any modifiers typically required by the state or payer for sterilization counseling and consent.

Policy Changes for Prescribing Controlled Substances Via Telehealth

For the end of the public health emergency, as declared by the Secretary of Health and Human Services:
- Opioid treatment centers and DATA-waived practitioners can prescribe buprenorphine to new and existing patients with opioid use disorder following an evaluation via telephone voice calls, without first performing an in-person or audio-video telemedicine evaluation.
- Practitioners that are registered with the Drug Enforcement Administration (DEA) can still temporarily prescribe schedule II-V controlled substances via telehealth for patients for whom they have not conducted an in-person evaluation. This temporary rule is still in effect till November 11, 2023.
- Any practitioners-patient telehealth relationship that has been or will be established on or before November 11, 2023, can still remain in effect till November 11, 2024.
See the HHS Telehealth page for more information and conditions for prescribing via telehealth.