How CMS has changed telehealth coding during Covid-19

Prior to the pandemic, CMS’ telehealth coverage was limited in scope and practice. CMS expanded coverage and waived restrictions to encourage broad adoption of telehealth and reimbursement parity for the duration of the public health emergency. Guidelines for stakeholders are outlined below.

Expanded telehealth services for the duration of the public health emergency

The list below includes CMS’ most recent updates to allowable services delivered via telehealth; for a comprehensive list of all Medicare covered telehealth services, visit the CMS website. Previously, these codes were non-covered services for telehealth and are temporary additions for the duration of the public health emergency.

Telephone services are considered telehealth for the duration of Covid-19

Medicare coverage prior to Covid-19 did not define telephone evaluation and management as telehealth services, and the codes were identified as non-covered services. CMS expanded coverage to include reimbursement for clinicians providing care via telephone for their patients and designated telephone evaluation and management as telehealth services (CPT 99441-99443). These codes are subject to the same place of service guidelines for all telehealth services. CPT codes 98966-98968are not designated as telehealth services and are not subject to a payment rate increase or coding guidelines outlined.

Telephone evaluation and management

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Medicare, “Telehealth,”https://www.medicare.gov/coverage/telehealth; CMS, “Medicare Telemedicine Health Care Provider Fact Sheet,”https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet; CMS, Trump Administration Issues Second Round of Sweeping Changes to Support U.S. Healthcare System During COVID 19 Pandemic,” https://www.cms.gov/newsroom/press-releases/trump-administration-issues-second-round-sweeping-changes-support-us-healthcare-system-during-covid

CMS, “Physicians and Other Clinicians: CMS Flexibilities to Fight COVID19,” https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf; CMS, “Telehealth Services,” https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

CMS, “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to theCOVID19 Public Health Emergency,” https://www.cms.gov/files/document/covid-final-ifc.pdf; CMS, “Physicians and Other Clinicians:CMS Flexibilities to Fight COVID 19,” https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf; CMS, “TelehealthServices,” https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes; CMS, “Physicians and OtherClinicians: CMS Flexibilities to Fight COVID 19,” https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf