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 was 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