Telehealth

In This Section

Public and private payers have taken steps to increase the use of telehealth services since the start of the public health emergency (PHE). However, as the PHE continues to wind down, health care professionals must continue to find ways to appropriately code and bill for these services. Since the final release of the 2023 Medicare physician fee schedule rule by the CMS, there have been some significant telehealth policy changes that may affect coverage, billing, and reimbursement for services. Below is a summary of those changes.

Medicare Telehealth Policy Changes after PHE Ending

Permanent Changes

Coverage of two-way audio-video telecommunication for covered telehealth services
Coverage of audio-only telephone evaluation and management (E/M) services as a “bundled service” only; physicians will no longer be paid separately for these services
Coverage of audio-only telehealth services for mental health care
Addition of five new telehealth G-codes for prolonged E/M services and chronic pain management. Find these codes in the table below.

Code	Description
G0316	Prolonged hospital inpatient or observation care evaluation and management service(s) beyond the total time for the primary service; each additional 15 minutes by the physician or qualified health care professional, with or without direct patient contact (list separately in addition to CPT codes 99223, 99233, and 99236 for hospital inpatient or observation care evaluation and management services)
G0317	Prolonged nursing facility evaluation and management service(s) beyond the total time for the primary service; each additional 15 minutes by the physician or qualified health care professional, with or without direct patient contact (list separately in addition to CPT codes 99306 and 99310 for nursing facility evaluation and management services)
G0318	Prolonged home or residence evaluation and management service(s) beyond the total time for the primary service; each additional 15 minutes by the physician or qualified health care professional, with or without direct patient contact (list separately in addition to CPT codes 99345 and 99350 for home or residence evaluation and management services)
G3002	Chronic pain management and treatment monthly bundle including diagnosis and assessment and monitoring. An initial face-to-face visit at least 30 minutes long provided by a physician or other qualified health professional is required; the first 30 minutes must be personally provided by a physician or other qualified health care professional per calendar month. A minimum of 30 minutes must be met or exceeded.
G3003	Each additional 15 minutes of chronic pain management and treatment by a physician or other qualified health care professional per calendar month (list separately in addition to code for G3002)

Ending 151 Days after PHE Ending

Reimbursement for audio-only evaluation and management (E/M) services (CPT codes 99441–99443)
Exemption of the six-month rule for telehealth health services for mental health care. Once this exemption is removed, Medicare will cover telehealth services for mental health care delivered while the patient is home as long as an in-person exam within six months of the initial telehealth visit is conducted; the visit is for the purposes of diagnosis, evaluation, or management of a mental health condition; and an in-person visit is conducted at least once every 12 months.
Extension of the temporary telehealth codes coverage
Addition of 54 codes to the category 3 Medicare Telehealth list

Ending at the End of 2023

The use of virtual direct supervision. Certain types of services (eg, diagnostic tests and services incident to physician or practitioner’s professional services) must be furnished under the direct supervision of a physician or practitioner. Direct supervision requires the supervising professional to be physically present in the same office suite as the supervisee and immediately available to furnish assistance throughout the performance of the procedure.
Use of modifier 95 along with the place of service code corresponding to where the telehealth service would have been furnished in person

Individual payer policies vary by plan. Check your payer’s website for an updated telehealth policy change.

Medicaid Policy Changes

Medicaid telehealth policies will vary state to state. The flexibilities available to states around telehealth, including modalities and originating site, were available to states prior to the pandemic and will continue to be available to states when the PHE concludes. For information on your state Medicaid telehealth policies, visit the Center for Connected Health Policy website.