- Many payers and practices use the broad term telehealth to describe services that are not done face-to-face with a patient
- CMs describes telehealth services as non-face-to-face services that are on its telehealth list
- During the public health emergency, CMS eased the rules related to telehealth
- The flexibilities remain in effect for RHCs and FQHCs for all of 2025.
- For all others, Congress extended telehealth until March 31, 2025.
The list of telehealth services is found in two places: CMS’s list of telehealth services and CPT’s list of CPT codes that could be reported via telehealth, in Appendix P of the CPT book. Both CMS and CPT defined telehealth as using a real-time, interactive audio and video communication system. CPT defined modifier 95 as “synchronous telemedicine service rendered via a real-time audio and visual telecommunications system.” CMS’s list includes HCPCS codes.
And, prior to the public health emergency, Medicare only covered telehealth services in medically underserved areas, and required that the patient go to a local medical facility (originating site) to receive telehealth services. Telehealth from home wasn’t covered. That changed with a release of waivers in mid-March, and a new rule published 3/30/2020, making the changes retroactive to early March.
Communication-based technology services (CBTS)—not telehealth
CMS began paying for services that used communication technology, but didn’t meet the criteria of telehealth. The patient wasn’t required to be in an underserved area and there was no requirement for real-time audio and visual communication. These included the brief virtual check-in HCPCS codes G2010 and G2012, and on-line digital E/M, 99421—99423. These are not on the telehealth list, are not considered to be telehealth services and do not require modifier 95. The don’t meet the definition of modifier 95, in the first paragraph of this article.
CMS updates the telehealth list annually
The old CMS telehealth list had two columns: code and description.
The March 30 telehealth list had three columns: code, description and a status column with this notation on some rows “Temporary Addition for the PHE for the COVID-19 Pandemic.”
The latest telehealth list has five columns: code, description, status and two new columns. One is “Can audio-only interactions meet requirements?” If so, there is a yes on that row. The fifth column is titled “Medicare payment limitations,” and there are a few rows in which the service is noted to be non-covered or bundled.