Quick Reference Guide for billing Telemedicine during COVID 1

April 21, 2020

By Dan Crane, CEO and Melissa Billman, Billing Director for C E Medical Group

There have been various updates from CMS over the last two months regarding telemedicine.  This includes telemedicine visits, virtual check ins, e-visits and phone calls.  This blog is intended to provide a quick reference to some of those updates, tips we have discovered as we code and bill on behalf our physician groups across the country. 

Recent updates from CMS include clarifying that Medicare should now be billed with place of service that would have been billed if the patient was seen in person with a modifier 95 and if working from home, the home address of the provider’s home does not need to be enrolled.  CMS has also updated and expanded the list of covered services. Other updates include coinsurance and deductible now apply to all telemedicine however providers are allowed to waive or discount patient responsibility.  In addition to expanding the list of services covered, CMS has allowed other ways to provide virtual services beyond just audio/visual tools.

The following is a list of the types of services:

Who can provide telemedicine services?

Qualified healthcare professionals able to bill telehealth include:

  • Physicians and Physician Assistants
  • Nurse Practitioners
  • Clinical Psychologists
  • Registered dieticians and nutritionists
  • Certified Nurse Anesthetists
  • Certified Midwives
  • Clinical Social Workers
  • Non-Eligible Providers:
  • Physical Therapist
  • Speech Therapist
  • Occupational Therapist

In the latest release from CMS, some therapy codes have been released on the expanded list but these cannot be billed under a PT, OT or SLP, they can only be billed under the providers listed above.

Direct supervision revision

During the pandemic, the definition of supervising provider has been revised. It used to read “direct supervision of a physician means that the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure”

It now reads “For the duration of the PHE for the COVID-19 pandemic, direct supervision to be provided using real-time interactive audio and video technology.”

All levels of E/M may be provided under direct supervision for telehealth.


Telephone visits:

When only audio visits can be provided a temporary waive changes these codes from non-covered to covered codes:

  • 98966-98968-telephone assessment and management service, time based
  • 99441-99443-telephone evaluation and management service, time based

We recommend that the best practice is to always try and perform audio AND video first to ensure proper care of the patient and only use telephone visits when there are technical difficulties.  Also keep in mind that reimbursement is less than the telemedicine, which now pay standard E&M rates.

Make sure you do not have a related E/M service provided within the previous 7 days or the telephone call leads to an E/M service or procedure within the next 24 hours of that call.

Documentation Guidelines

  • Document the type of telemedicine service you provided. (Phone call, audio/video, email, patient portal, virtual visits).
  • Try to keep your documentation as close as possible to the same as any of your face-to-face documentation.
  • Document verbal consent to perform the telemedicine services.
  • Be sure to include a statement indicating that the services were provided via telemedicine.

Documentation should also include:

  • Provider location
  • Patient location
  • Any names of any others that are participating in the telemedicine service and their role. (ex. Patient’s spouse, John, joined the telehealth service today to understand his wife’s plan of care with the patient’s approval)
  • Include the amount of clinical staff and physician time for the face-to-face patient visit
  • Start and stop time
  • Total time
  • Discussion
  • Response from the patient

Many private insurance compnaies have adopted these new CMS updated guidelines but check with each payor to esure your practice is complient and will get paid for your provider’s services. 

C E Medical Group is a national billing and consulting firm, specializing in serving pain medicine services.  Please contact the authors for additional questions or support at djcrane@cemedicalgroup.com or melissab@cemedicalgroup.com