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Billing Medicare Telehealth during COVID-19 PHE

Billing Medicare Telehealth during COVID-19 PHE

During the COVID-19 Public Health Emergency (PHE), reimbursements for telehealth continue to evolve. The federal government, state Medicaid programs, and private insurers have expanded coverage for virtual health care services. During the COVID-19 public health emergency, any health care provider who is eligible to bill Medicare can bill for telehealth services regardless of where the patient or provider is located. In this article, we shared revised Medicare Telehealth billing and coding guidelines which will help in billing Medicare telehealth during COVID-19 PHE.

Changed Telehealth Policies

The federal government announced a series of policy changes that broaden Medicare coverage for telehealth during the COVID-19 public health emergency. Legislation was recently passed that gives a runway of 151 days after the end of the PHE before any policy and regulation changes take place. Some important changes to Medicare telehealth coverage and reimbursement during this period include:


No geographic restrictions for patients or providers

Eligible providers

All health care providers who are eligible to bill Medicare can bill for telehealth services, including Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)

Eligible services

See this list of telehealth services from the Centers for Medicare & Medicaid Services


Providers can reduce or waive patient cost-sharing (co-payments and deductibles) for telehealth visits


Providers can furnish services outside their state of enrollment. For questions about new enrollment flexibilities, or to enroll for temporary billing privileges, use this list of Medicare Administrative Contractors (MACs) to call the hotline for your area


The 2022 Physician Fee Schedule has codified the ability for behavior health services to do audio only. It is still required to complete an in-person appointment every 6 months.

Billing for Medicare Fee-for-Service Claims

More Medicare Fee-for-Service (FFS) services are billable as telehealth during the COVID-19 public health emergency. Medicare added over one hundred CPT and HCPCS codes to the telehealth services list for the duration of the COVID-19 public health emergency. You will find list of telehealth services covered by Medicare here. Telehealth visits billed to Medicare are paid at the same Medicare Fee-for-Service (FFS) rate as an in-person visit during the COVID-19 public health emergency.

Coding Guidelines

Telephone visits and audio-only telehealth

Medicare increased payments for certain evaluation and management visits provided by phone for the duration of the COVID-19 public health emergency:

  • Telehealth CPT codes 99441 (5-10 minutes), 99442 (11-20 minutes), and 99443 (20-30 minutes)
  • Reimbursements match similar in-person services, increasing from about $14-$41 to about $60-$137, retroactive to March 1, 2020
  • In addition, Medicare is temporarily waiving the audio-video requirement for many telehealth services during the COVID-19 public health emergency. Codes that have audio-only waivers during the public health emergency are noted in the list of telehealth services. Medicare is establishing new billing guidelines and payment rates to use after the emergency ends.

Place of Service codes and modifiers

When billing telehealth claims for services delivered on or after January 1, 2022, and for the duration of the COVID-19 emergency declaration:

  • Include Place of Service (POS) equal to what it would have been had the service been furnished in person.
  • Medicare hasn’t identified place of service modifier 10 (PDF) for use when the patient is in their home. If they are located in any other location, utilize place of service modifier 02.
  • Append modifier 95 to indicate the service took place via telehealth.
  • The CR modifier is not required when billing for telehealth services.

Hospital billing for remote visits

Hospitals can bill HCPCS code Q3014, the originating site facility fee, when a hospital provides services via telehealth to a registered outpatient of the hospital. Under the emergency waiver in effect, the patient can be located in any provider-based department, including the hospital, or the patient’s home.

Medisys Data Solutions is a leading medical billing company providing complete billing and coding services for various medical billing specialties. Our team of expert medical biller and coders are well versed with revised Medicare telehealth billing guidelines during COVID-19 PHE. We can assist you in receiving accurate Medicare reimbursement for telehealth services. To know more about our Medicare telehealth billing services, contact us at / 302-261-9187

Reference: Billing for telehealth during COVID-19

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