Billing and reimbursement during the COVID-19 Public Health Emergency

The federal government announced a series of policy changes that broaden Medicare coverage for telehealth during the COVID-19 Public Health Emergency. Some important changes to Medicare telehealth coverage and reimbursement during this period include:

• Location: No geographic restrictions for patients or providers
• Eligible providers: All health care providers who are eligible to bill Medicare can bill for telehealth services, including Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)
• Eligible services: See this list of telehealth services from the Centers for Medicare & Medicaid Services
• Cost-sharing: Providers can reduce or waive patient cost-sharing (copayments and deductibles) for telehealth visits
• Licensing: Providers can furnish services outside their state of enrollment. For questions about new enrollment flexibilities, or to enroll for temporary billing privileges, use this list of Medicare Administrative Contractors (MACs) to call the hotline for your area.
• Modality: Some telehealth services only require a telephone (see the Medicare Fee-for-Service section below for more details about audio-only services).

For details about these and other Medicare waivers and flexibilities in effect, see:

• Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19 (PDF) — from the Centers for Medicare & Medicaid Services
• COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing (PDF) — from the Centers for Medicare & Medicaid Services
• COVID-19 Telehealth Coverage Policies — from the National Policy Telehealth Resource Center

Tip: For questions on Medicare or Medicaid reimbursement, contact the National Telehealth Policy Resource Center .

Telehealth visits are paid at the same Fee-for-Service rate as an in-person visit during the COVID-19 Public Health Emergency.

When billing telehealth claims for services delivered on or after March 1, 2020, and for the duration of the COVID-19 Public Health Emergency:

• Include Place of Service (POS) equal to what it would have been had the service been furnished in person
• Append modifier 95 to indicate the service took place via telehealth

The CR modifier is not required when billing for telehealth services.

For details about billing Medicare, including how to bill for counseling and COVID-19 testing, see:

• Medicare Fee-For-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19) (PDF) — from the Centers for Medicare and Medicaid Services

Audio-only telephone visits

The Centers for Medicare & Medicaid Services increased Medicare payments for certain audio-only visits — audio-only telephone evaluation and management services and behavioral health counseling and educational services — to match payments for similar in-person services. Payments for audio-only telephone evaluation and management services increased from about $14-$41 to about $46-$110, retroactive to March 1, 2020.

For the full list of telehealth services, including which services can be provided as audio-only visits, see this list of telehealth services from the Centers for Medicare & Medicaid Services.

Hospital billing for remote services

Hospitals can bill HCPCS code Q3014, the originating site facility fee, when a hospital provides services via telehealth to a registered outpatient of the hospital.

Under the emergency waiver in effect, the patient can be located in any provider-based department, including the hospital, or the patient’s home.

For more details, see:

• COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing (PDF, see “Hospital Billing for Remote Services” section) — from the Centers for Medicare & Medicaid Services

FQHCs and RHCs can provide services as a distant site provider using telehealth. Any service that Medicare has approved to be furnished via telehealth can be provided by an FQHC or RHC during the COVID-19 Public Health Emergency. See the full list of telehealth services from the Centers for Medicare & Medicaid Services.

During the COVID-19 Public Health Emergency:

• FQHCs and RHCs can bill Medicare for telehealth services as distant site providers, at a reimbursement rate of $92.03, retroactive to January 27, 2020. See these guidelines from the Centers for Medicare and Medicaid Services for details.
• The patient’s home is an eligible originating site during the COVID-19 Public Health Emergency (as of March 6, 2020).
• Coverage for virtual communication services has been expanded to include online digital evaluation and management. These services are not considered telehealth and are reimbursed at a different rate (see details under “Billing codes for FQHC or RHC virtual communication services”).

Billing codes for FQHC or RHC telehealth services

For FQHC and RHC telehealth services provided on or after July 1, 2020 through the end of the COVID-19 Public Health Emergency, use the following:

Audio-only services (CPT codes 99441, 99442, and 99443) are billable under the new G2025 code.

Billing codes for FQHC or RHC virtual communication services

FQHCs and RHCs can bill for digital evaluation and management services during the COVID-19 Public Health Emergency:

• Use HCPCS code G0071 alone or with other payable services when submitting claims for virtual communication services.
• The new payment rate for all claims submitted with code G0071 is $24.76, and covers services delivered on or after March 1, 2020.
• The newly covered online digital evaluation and management CPT codes (e-visits) include:
  • 99421 (5-10 minutes over a 7-day period)
  • 99422 (11-20 minutes over a 7-day period)
  • 99423 (21 minutes or more over a 7-day period)
• Virtual check-ins (HCPCS code G2012) and remote evaluation of recorded videos or images (HCPCS G2010) are also reimbursable using the new G0071 code.

For more details about billing as an FQHC or RHC during the COVID-19 Public Health Emergency, see:

• New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PDF)— from the Centers for Medicare and Medicaid Services
• Federally Qualified Health Centers & Rural Health Clinics Acting as Distant Site Providers in Medicare (PDF) — from the National Policy Telehealth Resource Center

Medicaid coverage differs from state to state. Most states have expanded Medicaid coverage for telehealth during the COVID-19 Public Health Emergency. For instance, many states are now allowing:

• Telehealth services via telephone, electronic and virtual means
• Home as the originating site for telehealth
• Coverage and pay parity for telehealth services

For the latest information on state-specific billing and reimbursement policies, the National Policy Telehealth Resource Center has created an inventory of COVID-19 Related State Actions that details each state’s requirements for billing telehealth during the emergency period (and in some cases, even after the emergency declaration ends).

The federal government is reimbursing health care providers for testing and treating uninsured individuals for COVID-19 — including related services provided via telehealth.

Health care providers, including health centers, can submit claims for eligible COVID-19 services (e.g., testing an uninsured patient for COVID-19 or treating a patient with a primary COVID-19 diagnosis) provided on or after February 4, 2020. Reimbursements, subject to funding availability, are generally paid at Medicare rates.

Visit the Health Resource and Services Administration’s (HRSA) COVID-19 Uninsured Program Portal to learn more about the program or submit a claim.

For more details, see:

• COVID-19 - Resources & Support - Coverage Details — from the Health Resources and Services Administration
• COVID-19 - Resources & Support - Billing Codes — from the Health Resources and Services Administration
• FAQs for COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing and Treatment of the Uninsured — from the Health Resources and Services Administration

Once FDA-authorized COVID-19 vaccines are available, reimbursements for uninsured patients will also be available through this program.

Most insurance providers cover at least some form of telehealth service. Contact the insurance providers you accept to see if they cover reimbursement for any telehealth services.

There are additional code changes for COVID-19 related care that cover telehealth, virtual/digital, audio-only, and in-person. You should verify each payer’s policy and ask patients to verify their coverage ahead of appointments.

• COVID-19: Coding Scenarios — from the American Academy of Family Physicians