Telehealth services

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.

The CMS Telehealth & Remote Patient Monitoring MLN Booklet was recently updated to incorporate the most current Medicare requirements. Below is a summary of key points of telehealth services.

Technology requirements

Interactive telecommunications system means multimedia communications equipment including, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.

Under current law, beneficiaries may continue to receive audio-only telehealth services in their homes through December 31, 2027. Starting January 1, 2028, physicians and practitioners may use two-way, real-time audio-only communication technology for behavioral health services furnished to a patient in their home, provided that the furnishing physician or practitioner is technically capable of using audio-video communication technology and that the beneficiary is not capable of or does not consent to using audio-video communication technology. Audio-only can be used for both new and established patients. Beneficiaries who are receiving remote mental health services, as defined in the CY 2023 and 2024 OPPS Final Rules, furnished by hospitalemployed staff in their homes may also receive these services via audio-only communication technology.

Distant site

A distant site is the location from where a physician or practitioner provides telehealth. Through December 31, 2027, all providers who are eligible to bill Medicare for professional services can provide distant site telehealth.

Distant site practitioners can provide telehealth services from their home and in many cases do not need to report their home address. Practitioners who furnish telehealth services from their homes but have a physical practice location are not required to report their home address on their Medicare enrollment application. For further information, refer to Telehealth enrollment scenarios.

Eligible providers

The following distant site professionals eligible to bill for telehealth services include:

The following distant site health care professionals eligible to bill telehealth services through December 31, 2027:

Note: Distant site professionals may be limited by state scope of practice.

Originating site

An originating site is the location where a patient is located while receiving physician or practitioner medical services through telehealth.

Through December 31, 2027, 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.

HCPCS Code Q3014 describes the Medicare telehealth originating site facility fee. The Medicare originating site facility fee amount for CY 2025 is $31.01 and for CY 2026 is $31.85.

An originating site facility fee is 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).

Billing and payment methodology for originating site:

For physician and practitioner offices, the only payable setting for originating site is office, place of service (POS) 11, and the payment amount is the lesser of 80% of the actual charge or 80% of the originating site facility fee, regardless of geographic location.

An originating site can include the home of individual for certain purposes related to ESRD, SUDs and mental health or a mobile stroke unit.

Billing of telehealth services

A list of telehealth services is available on the CMS website.

Modifiers

Telehealth modifiers provide information regarding the modality of delivery by the distant site for 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.

A list of telehealth services is available on the CMS website. Append the following modifiers to services outlined on this listing, when applicable.

Place of service (POS)

Report the following POS as appropriate for telehealth services to indicate where the patient was located when receiving telehealth services:

Outpatient therapy, DSMT and medical nutritional therapy (MNT) services

CMS is continuing to align requirements for payment for services furnished remotely by hospital staff to beneficiaries in their homes, including remotely furnished outpatient therapy services, DSMT, and MNT services, with requirements for Medicare telehealth services. Therefore, through December 31, 2027, hospitals can continue to bill for these services. Starting January 1, 2028, hospitals may no longer bill for these services when furnished remotely by hospital staff to beneficiaries in their homes.

Teaching physicians

In the CY 2026 Physician Fee Schedule final rule, CMS established beginning January 1, 2026, they are continuing to allow teaching physicians to have a virtual presence in all teaching settings, but only for services furnished as a Medicare telehealth service. This will continue to permit teaching physicians to have a virtual presence during the key portion of the Medicare telehealth service for which payment is sought, through audio/video real-time communications technology, for all residency training locations.

Consent for care management and virtual communication services

CMS requires patient consent for all services, including non-face-to-face services. Providers may obtain patient consent at the same time the provider initially provides the services. Direct supervision is not required to obtain 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.

Acute hospital care at home

The Acute Hospital Care at Home (AHCaH) initiative 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 expansion relies heavily on telehealth for hospitals to provide inpatient services including routine services, outside the hospital.

This was extended most recently by the Consolidated Appropriations Act, 2026. For all hospitals with active AHCAH waivers, all inpatients must be discharged or returned to the hospital on September 30, 2030, in the absence of Congressional action to extend the initiative. CMS will no longer accept waiver requests for participation in the AHCAH initiative after September 1, 2030.

RHCs and FQHCs

Non-behavioral health visits furnished via telecommunication technology under the methodology that has been in place for these services during and after the COVID-19 PHE through December 31, 2026; RHCs and FQHCs can continue to bill for RHC and FQHC services furnished using telecommunication technology by reporting HCPCS code G2025.

FQHCs and RHCs bill their Part A MAC using the FQHC and RHC bill type and provider number.

Additional information on distant site billing for FQHCs and RHCs can be found in the following resources:

References