CPT® has two modifiers for telemedicine. CMS and private payers regularly change their instructions about using these modifiers and what place of service to use. In 2024, CMS is no longer requiring modifier 95 on claims, but is requiring using POS 02 or POS 10.
- Modifier 95 is for use with real-time, audio/visual visits.
- Modifier 93 is for audio-only telehealth services
Modifier GT is used by distant site practitioners billing telehealth under the CAH Optional Payment Method II, on institutional claims.
Modifier 93: Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-only Telecommunication System
- These are listed in Appendix T of the CPT book
Modifier 95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunication System
- These are listed in Appendix P of the CPT book.
CMS has a list of services that may be performed via telehealth, and some may be done via audio only. You can download it from their site. There is a column that indicates if the service may be performed via audio only, and if the service is permanently added to the telehealth list or is provisional.
Private payers have continuously updated their telehealth rules, and each must be researched separately.
Place of Service: The MLN Matters article updated April 2024 (MLN901705) provides this information about POS:
“Professional billing
Starting 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, we pay for telehealth services you provide to patients in their homes at the non-facility PFS rate.”
CPT Changes in 2025:
CPT® is adding 17 new CPT codes for audio only, audio/visual visits. These are divided into new and established patient visits and with either time or MDM definitions. The bad news: CMS is proposing to give 16 of these an invalid status indicator. One would replace G2012 brief communications technology check in. CMS would recognize that code and delete G2012 if that passes in the Final Rule to be released in November for 2025 policy.
CMS released its coding proposals for 2025 and stated they don’t believe they have the statutory authority to continue the PHE flexibilities unless Congress changes the law. CMS says this every year, and up until now, Congress has passed end of year laws that continue to allow the patient to receive care from their home in all geographic locations. Plainly speaking: if Congress doesn’t include this in their end of year budget reconciliation bill or another bill, patients will no longer be able to receive telehealth in their homes but will need to go to a facility (originating site) and will only be able to receive telehealth if they are not living in a metropolitan statistical area (MSA) as defined by the office of Management and Budget or are living in a geographic Health Professional Shortage Area.
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