Telehealth services are defined as services a physician or practitioner provides via two-way, interactive technology (or telehealth). Telehealth substitutes for an in-person visit and generally involves two-way, interactive technology permitting communication between the practitioner and patient.
For most non-behavioral or mental telehealth, you must use two-way, interactive, audio-video technology. The Consolidated Appropriations Act, 2023 allows you to use audio-only telehealth for some non-behavioral or mental telehealth through December 31, 2024.
For behavioral or mental telehealth, you may use two-way, interactive, audio-only technology.
A distant site is the location from where a physician or practitioner provides telehealth. Through December 31, 2024, all providers who are eligible to bill Medicare for professional services can provide distant site telehealth.
The following distant site practitioners can furnish and receive payment for covered telehealth services include:
Nurse practitioners (NPs)
Physician assistants (PAs)
Clinical nurse-midwives (CNM)
Clinical nurse specialists (CNS)
Certified registered nurse anesthetists (CRNAs)
Clinical psychologists (CPs)
Clinical social workers (CSWs)
Registered dietitians (RDs)
Nutrition professionals
Audiologists
Occupational therapist (OT)
Physical therapist (PT)
Speech language pathologist (SLP)
Beginning with dates of service on and after January 1, 2024:
Mental health counselors (MHC)
Marriage family therapists (MFT)
Note: CPs and CSWs cannot bill Medicare for psychiatric diagnostic interview examinations with medical services or medical evaluation and management (E/M) services. CPT codes include 90792, 90833, 90836, and 90838.
An originating site is the location where a patient is located while receiving physician or practitioner medical services through telehealth. Before the COVID-19 public health emergency (PHE), patients needed to receive telehealth at an originating site located in a certain geographic location.
Through December 31, 2024, all patients can receive telehealth wherever they are located. They do not need to be at a designated originating site and there are no geographic restrictions.
For dates of service after December 31, 2024:
Non-behavioral or mental telehealth -- There may be originating site requirements and geographic location restrictions.
Behavioral or mental telehealth -- All patients can continue to receive telehealth wherever they are located, with no originating site requirements or geographic location restriction.
HCPCS Code Q3014 describes the Medicare telehealth originating sites facility fee. The Medicare originating site facility fee amount for CY 2024 is $29.96. Modifier 95 is not used with Q3014.
An originating site facility fee can only be billed when the patient is in a healthcare facility receiving telehealth. Medicare makes payment to the distant site practitioner for the professional services.
Note: If the patient is within a hospital and receives a hospital outpatient clinic visit (including a mental or behavioral health visit), from a practitioner located in the same physical location, the hospital would bill for the clinic visit (HCPCS code G0463).
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|
|
|
Outpatient hospital |
Outside of outpatient prospective payment system (OPPS) |
13X |
078X |
Inpatient hospital |
Outside diagnostic related group codes (DRGs) |
12X |
078X |
Critical access hospital (CAH) |
Separate from cost based (80% or the originating site facility fee) |
12X or 85X |
078X |
Federally qualified health center (FQHC) or rural health center (RHC) |
Separate from prospective payment system (PPS) or all-inclusive rate (AIR) |
77X or 71X |
078X |
Hospital-based or CAH-based renal dialysis center |
In addition to ESRD PPS or monthly capitation payment |
72X |
078X |
Skilled nursing facility (SNF) |
Outside of the SNF PPS (not subject to consolidated billing) |
22X or 23X |
78X |
Community mental health center (CHMC) |
Not a partial hospitalization service (or used to determine payment for partial hospitalization). Not bundled in per diem |
76X |
078X |
A listing of Medicare Telehealth Services are available on the CMS website.
There are two categories for coverage -- permanent and provisional.
Permanent means services will remain on the telehealth listing.
Services listed under provisional will have refinements to telehealth policies based on certain provisions.
Telehealth modifiers should be submitted with distant site telehealth services. Generally, interactive audio and video communications must be used to permit real-time communication between distant site physician or practitioner and patient. Patient must be present and participating in telehealth visit.
Modifier |
Description |
93 |
Telehealth modifier defined as "synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system". This modifier should only be used by Opioid Treatment Programs (OTPs) and Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs): Opioid Treatment Programs (OTPs) report on claims for counseling and therapy provided using audio-only technology. RHCs and FQHCs report modifier on claims for mental health visits for audio-only technology |
95 |
Telehealth modifier defined as synchronous telemedicine service rendered via real-time Interactive audio and video telecommunications system. Opioid Treatment Programs (OTPs) report on claims for counseling and therapy provided using audio-video only technology: For institutional billing, use modifier 95 for dates of service on and after January 1, 2024, through December 31, 2024, when: The clinician is in the hospital and the patient is in their home. Outpatient therapy provided via telehealth by PTs, OTs or SLPs employed by hospitals. Note: Providers should continue to bill claims for telehealth services with the POS if the service had been done in person and modifier 95 through December 31, 2023. |
G0 (zero) |
Telehealth services furnished for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke. Valid for: Telehealth distant site codes billed with place of service (POS) code 02; or CAH method II (revenue codes 096X, 097X, or 098X); or Telehealth originating site facility fee, billed with HCPCS code Q3014. |
GQ |
Telehealth service rendered via asynchronous telecommunications system. |
GT |
Telehealth service via interactive audio and video telecommunication systems. * *Only allowed on institutional claims billed by CAH method II providers. |
FQ |
The service was furnished using audio-only communication technology. Use when the patient is unable to use audio and video communications. Note: This modifier should only be used by RHCs and FQHCs. Report modifier for mental health visits using audio-only technology |
Providers should continue to bill claims for telehealth services with the POS if the service had been done in person and modifier 95 through December 31, 2023.
For dates of service on and after January 1, 2024, use:
POS 02 -- Telehealth Provided Other than in Patient’s Home
Descriptor: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
POS 10 -- Telehealth Provided in Patient’s Home
Descriptor: The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
Starting January 1, 2024, telehealth services provided to patients in their homes will be reimbursed at the non-facility PFS rate.
Distant site practitioners are allowed to bill for DSMT services.
These include RDs, nutrition professionals, physicians, NPs, PAs, and CNSs who personally provide services as part of DSMT entity.
DSMT insulin injection training (for initial or follow-up training) is allowed to be provided via telehealth when it aligns with clinical standards, guidelines, or best practices.
CMS IOM Pub. 100-04 Medicare Claims Processing Manual, Chapter 12, section 190.3.6
Institutional providers can continue to bill for PT, OT, SLP, DSMT and MNT services provided remotely in the same way they could during the PHE through the end of CY 2023.
Hospitals and other providers of PT, OT, SLP, DSMT and MNT services remaining on the Medicare Telehealth Services List can continue to bill for these services when provided remotely in the same way they could during the PHE through the end of CY 2024, except that:
For outpatient hospitals, patients’ homes no longer need to be registered as provider-based entities to allow for hospitals to bill for these services.
Except for Critical Access Hospitals (CAHs) electing Method II, the 95 modifier is required on claims from all providers reassigning their benefits.
Teaching physicians can continue to use audio or video real-time communications technology when the resident provides telehealth in all residency training locations through the end of CY2024.
CMS requires patient consent for all services, including non-face-to-face services. Providers may obtain patient consent at the same time you initially provide the services. Direct supervision is not required to get consent.
In general, auxiliary personnel under general supervision of the billing practitioner can obtain patient consent for these services. The person getting consent can be an employee, independent contractor, or leased employee of the billing practitioner.
The Acute Hospital Care at Home initiative (AHCaH) is a flexibility to allow hospitals to expand their capacity to provide inpatient care in an individual’s home implemented by CMS during the COVID-19 PHE. This relies heavily on telehealth for hospitals to provide inpatient services including routine services, outside the hospital.
Under the CAA, 2023, the AHCaH initiative has been extended through December 31, 2024. Hospitals can continue to apply to participate in the initiative. If an individual is receiving care in a participating hospital and meets the requirements to receive inpatient care at home, they can continue to do so.
Independent and provider based FQHCs and RHCs bill their Part A MAC using the FQHC and RHC bill type and provider number.
Report revenue code 078X when billing for the originating site facility fee for both FQHCs and RHCs.
Additional information on distant site billing for FQHCs and RHCs can be found in the following resources: