Billing and coding Medicare Fee-for-Service claims
More Medicare Fee-for-Service (FFS) services are billable as telehealth during the COVID-19 public health emergency. The Administration’s plan is to end the COVID-19 public health emergency (PHE) on May 11, 2023. Read the latest guidance on billing and coding FFS telehealth claims.
The Centers for Medicare and Medicaid Services has released the final rule for the 2023 Medicare Physician Fee Schedule.
Telehealth codes covered by Medicare
Medicare added over one hundred CPT and HCPCS codes for the duration of the COVID-19 public health emergency.
Telehealth visits billed to Medicare are paid at the same Medicare Fee-for-Service (FFS) rate as an in-person visit during the COVID-19 public health emergency.
Coverage after COVID-19 ends
Some telehealth codes are only covered until the Public Health Emergency Declaration ends.
Medicare is covering a portion of codes permanently under the 2023 Physician Fee Schedule.
This National Policy Center - Center for Connected Health Policy fact sheet (PDF) summarizes temporary and permanent changes to telehealth billing.
Changes to policies impacted by the 2022 Consolidated Appropriations Act are summarized in this reference guide by the Center for Connected Health Policy (PDF). The policies listed focus on temporary changes to Medicare telehealth in response to COVID-19.
Coding claims during COVID-19
Telephone visits and audio-only telehealth
Medicare increased payments for certain evaluation and management visits provided by phone for the duration of the COVID-19 public health emergency:
- Telehealth CPT codes 99441 (5-10 minutes), 99442 (11-20 minutes), and 99443 (20-30 minutes)
- Reimbursements match similar in-person services, increasing from about $14-$41 to about $60-$137, retroactive to March 1, 2020
In addition, Medicare is temporarily waiving the audio-video requirement for many telehealth services during the COVID-19 public health emergency.
Codes that have audio-only waivers during the public health emergency are noted in the list of telehealth services. Medicare is establishing new billing guidelines and payment rates to use after the emergency ends.
Place of Service codes and modifiers
When billing telehealth claims for services delivered on or after January 1, 2022, and for the duration of the COVID-19 emergency declaration:
- Include Place of Service (POS) equal to what it would have been had the service been furnished in person.
- Medicare hasn’t identified place of service modifier 10 (PDF) for use when the patient is in their home. If they are located in any other location, utilize place of service modifier 02.
- Append modifier 95 to indicate the service took place via telehealth .
The CR modifier is not required when billing for telehealth services.
Hospital billing for remote visits
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
COVID-19 testing and online counseling
For details about how to bill Medicare for COVID-19 counseling and testing, see:
- Medicare Fee-For-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19) — from the Centers for Medicare & Medicaid Services
Common telehealth billing mistakes
Avoiding mistakes in the reimbursement process can help implementing telehealth into your practice a smoother experience.
Incorrect billing codes
As of March 2020, more than 100 telehealth services are covered under Medicare. However, some CPT and HCPCS codes are only covered until the current Public Health Emergency Declaration ends.
Using the wrong code can delay your reimbursement. This can happen for a variety of reasons, such as a misunderstanding of what code applies to what service or input error.
Stay up to date on the latest Medicare billing codes for telehealth to keep your practice running smoothly.
Post-visit documentation must be as thorough as possible to ensure prompt reimbursement.
While there are many similarities between documenting in-person visits and telehealth visits, there are some key factors to keep in mind.
Make a note of whether the patient gave you verbal or written consent to conduct a virtual appointment.
Telephone codes are required for audio-only appointments, while office codes are for audio and video visits.
Time of visit
A common mistake made by health care providers is billing time a patient spent with clinical staff. Providers should only bill for the time that they spent with the patient.
Many states require telehealth services to be delivered in “real-time”, which means that store-and-forward activities are unlikely to be reimbursed. You can find information about store-and-forward rules in your state here .
Originating sites and distant sites
During the COVID-19 public health emergency, Medicare and some Medicaid programs expanded the definition of an originating site. In addition, Federally Qualified Health Centers and Rural Health Clinics can bill Medicare for telehealth services as a distant site.
More information about FFS billing
If you are looking for detailed guidance on what is covered and how to bill Medicare FFS claims, see:
- COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing (PDF) — from the Centers for Medicare & Medicaid Services
- Billing for Telehealth Encounters: An Introductory Guide on Fee-for-Service (PDF) – from the National Policy Center - Center for Connected Health Policy