Virtual communications are not considered telehealth
- These HCPCS codes were developed by CMS for virtual communication
- They are not on CMS’s list of telehealth services and do not use real-time, interactive, audio/visual communication
- They do require verbal consent; a single consent can be obtained for all communications based technology services annually for Medicare patients
- In 2025, G2012 is replaced by CPT code 98016
CMS said it doesn’t consider these to be telehealth services, although they are “technology-based.”
98016 Brief communication technology-based service
98016 Brief communication technology-based service, (eg, virtual check-in) by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion
98016 replaces HCPCS code G2012. It is part of the CPT series of telehealth codes in the series 98000–98016. CMS is recognizing this code, but the other codes in the series have a status indicator of invalid.
- This is a service provided by a physician or advanced practice nurse or physician assistant, not by clinical staff.
- It has low reimbursement.
- Notice the restrictions: it can’t be a follow up from an prior E/M within the past 7 days and can’t result in an office visit.
- When CMS developed the original HCPCS code, it was intended as a virtual check-in (think messaging via a portal or call) to determine if a visit was needed.
- CPT states not to report it for less than 5 minutes of discussion
G2252 11-20 minutes of medical discussion
This HCPCS code is still in effect.
G2252 Brief communication technology-based service, (eg, virtual check-in) by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion
G2010, store and forward
Did you ever want to send a picture to your doctor of your rash? Or that tick that was crawling up your arm? Well, now is your chance. Your doctor/NP/PA will be paid $12 or $13 to look at your picture or video!
This code has the same requirements that it does not arise from a service within the past 7 days or result in a service in the next 24 hours or next available appointment.
The practitioner looks at the image or video, and there is subsequent communication by the practitioner or staff member to the patient. Follow up is required. The follow up could be a portal message or a phone call. If the image is insufficient to make a determination, it can’t be billed.
It also requires consent (verbal, written or electronic) and the charge will be subject to co-insurance and deductible. It may only be provided to an established patient.
G2010 Remote evaluation of recorded video and/or images submitted by an established patient (e.g, store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment
Clinicians without E/M in their scope of practice
CMS also developed HCPCS codes for clinicians who can’t bill office visits or other E/M services but who are able to enroll in Medicare and report their services. This includes social workers, physical and occupational therapists, and speech language pathologists.
G2250 Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment
G2251 Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion
CPT® Codes (99421-99423) – and Payment for – Online Digital Evaluation and Management (E/M) Services
Additional resources
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