YOU NEED TO KNOW
TELEHEALTH FOR
PROVIDERS: WHAT
TABLE OF CONTENTS
Telehealth Basics ...........................2
What is telehealth? .................................2
When to use telehealth
..............................4
Types of telehealth
.................................5
Starting & Sustaining Telehealth .............. 7
Steps for using telehealth ............................7
Telehealth tips
...................................14
Considerations for various populations
.................17
People with disabilities
............................17
Non-English-speaking patients
......................18
Telehealth for rural populations
......................19
Telehealth for behavioral health
.......................21
Billing for Telehealth .......................23
Federal policies: Medicare...........................24
State policies: Medicaid
............................26
Documentation and coding tips
.......................28
Additional Resources ......................29
Technical assistance...............................29
Coverage to Care Telehealth for Providers: What You Need to Know 1
TELEHEALTH BASICS
What is telehealth?
Telehealth, sometimes referred to as telemedicine, is the use of
electronic information and telecommunications technologies to
extend care when you and the patient aren’t in the same place
at the same time. Technologies for telehealth include
videoconferencing, store-and-forward imaging, streaming media,
and terrestrial and wireless communications. Telehealth services
may be billed and paid differently, depending on the payer/insurer
you’re working with and your geographic location. Find more
information in Billing for Telehealth.
Telehealth allows health care providers to:
•
Increase continuity of care
•
Extend access to care beyond normal hours
•
Reduce patient and provider travel burden
•
Help overcome clinician shortages, especially among rural and
other underserved populations
•
Provide support for patients managing chronic health conditions
•
Screen patients with symptoms of COVID-19 and refer
as appropriate
•
Enable patients who are vulnerable to COVID-19 to continue
receiving medical care safely
•
Help stop the spread of infectious diseases
•
And more
2 Coverage to Care Telehealth for Providers: What You Need to Know 3
When to use telehealth
The appropriate use of telehealth may depend on the patient or situation, and it’s ultimately decided by
the provider. These are situations where providers may nd telehealth more, or less, appropriate:
4
Telehealth is likely appropriate for: Telehealth is less appropriate for:
General wellness visits Health concerns that require a procedure
Management of chronic conditions Abdominal pain
Discussion of test results Eye complaints
Counseling about diagnostic and therapeutic options Gynecologic complaints
Dermatology Dental complaints
Prescriptions for medicine Highly nuanced or multiple complex health concerns
Nutrition counseling
Any situation in which a physical exam would change
your recommendation
Mental health counseling
Types of telehealth
Live video – Also referred to as “real-time;” a two-way, face-to-face interaction
between a patient and a provider using audiovisual communications technology
Store-and-forward – Remote evaluation of recorded video and/or images
submitted by an established patient
E-visits – Non-face-to-face patient-initiated communications through an online
patient portal
Remote patient monitoring – Use of digital technologies to collect health
data from patients in one location and electronically transmit that information
securely to providers in a different location (data can include vital signs, weight,
blood pressure, blood sugar, pacemaker information, etc.)
Audio-only visits – Use of telephone for visits without video
Mobile health (mHealth) – Allows patients to review their personal health
data via mobile devices, such as cell phones and tablet computers, which
can be done from their home and assists in communicating their health status
and any changes; often includes use of dedicated application software (apps),
which are downloaded onto devices
Case-based teleconferencing – Method of providing holistic, coordinated,
and integrated services across providers; usually interdisciplinary, with one or
multiple internal and external providers and, if possible and appropriate, the
client and family members/close supports
Coverage to Care Telehealth for Providers: What You Need to Know 5
STARTING & SUSTAINING
TELEHEALTH
6
Step 1: Select a telehealth vendor
Identify any technology that you have access to already. For
example, your patient portal may have some type of telehealth
functionality built in. When researching additional options, you
may wish to consider:
•
How will the vendor protect personal health information?
•
Is a contract required?
•
Is any special equipment required?
•
Does it offer a waiting room feature?
•
Can staff or patients schedule visits through the platform?
•
Will patients provide consent to receive telehealth on the
platform itself?
•
Do patients need to download an app to have a
telehealth visit?
•
Does it offer end-to-end encryption?
Coverage to Care Telehealth for Providers: What You Need to Know 7
Spruce Health
Care Messenger
GoToMeeting
Amazon Chime
Updox
VSee
Zoom for
Healthcare
Doxy.me
Cisco Webex Meetings
/ Webex Teams
Google G Suite
Hangouts Meet
Skype for Business
/ Microsoft Teams
Covered health care providers that seek additional privacy protections for telehealth while using
video communication products should provide such services through technology vendors that are
HIPAA compliant and will enter into HIPAA business associate agreements (BAAs) in connection
with the provision of their video communication products. The list below includes some vendors that
represent that they provide HIPAA-compliant video communication products and that they will enter
into a HIPAA BAA.
Apple
FaceTime
Facebook
Messenger
video chat
Google
Hangouts
video
Zoom Skype
COVID-19 public health emergency (PHE) policy update
During the COVID-19 PHE, HHS’ Ofce for Civil Rights (OCR) released a Notication of Enforcement
Discretion for Telehealth to allow covered providers to use popular non-facing communication apps to
deliver telehealth during the COVID-19 PHE.
This Notication of Enforcement Discretion for Telehealth expires on May 11, 2023. There is a 90-calendar
day transition period for covered health providers to comply with HIPAA rules for the provision of
telehealth. The transition period starts on May 12, 2023 and expires at 11:59 p.m. on August 9, 2023.
8 9Telehealth for Providers: What You Need to Know Coverage to Care
Many of these apps are free for providers to use. Providers should notify patients that these third-
party apps potentially introduce privacy risks and should enable all available encryption and privacy
modes when using them.
Note: OCR has not reviewed the BAAs offered by these vendors, and this list does not constitute an
endorsement, certication, or recommendation of specic technology, software, applications, or products.
OCR also does not endorse any of the applications that allow for video chats listed above.
Step 2: Prepare for telehealth implementation
Establish a telehealth workow and protocols. Consider:
•
When you’ll be available for telehealth appointments
•
What services you’ll offer (if you’ll be offering behavioral health care, see
Telehealth for behavioral health)
•
How patients will schedule appointments
•
How you’ll access the information you need for each patient visit
•
Who will greet the patient rst when they join the visit — for example, you
may want a medical assistant to ask some initial questions before you join
•
How you’ll get consent from patients
•
How you’ll support patients who have limited English prociency (see
Considerations for various populations)
•
How you’ll support patients living with disabilities, such as hearing loss or
visual impairment (see Considerations for various populations)
•
How you’ll facilitate access to telehealth for all your patients and ensure
they get the most out of their visit (see Telehealth for rural populations and
Telehealth for all)
•
How you’ll support a caregiver or another person who needs to assist a patient
during the telehealth visit
•
How you’ll obtain payment after a visit
•
Who will monitor the sustainability and long-term success of your telehealth
program and adapt or modify the services based on patients’ needs and
your resources/capacity
Educate your patients about the availability of telehealth visits.
Some options include:
•
Updating your website
•
Sending an email to your patients
•
Sharing information via social media channels
•
Offering the services when patients call to schedule a visit
Create a Q&A sheet to share with patients or share the Telehealth: What to
Know for Your Family resource. Let patients know what to expect and what will
be expected of them.
If patients must download an app, prepare a script to help them download the
app and walk them through the platform. Become familiar with the platform
yourself so you can help troubleshoot during the visit.
Test your equipment before each visit to ensure there are no complications.
Enter the platform and check your audio and video. Remember to be in a
private space and remove any objects, like sticky notes, that may be blocking
your camera. If you’re using an interpreter, make sure their equipment is also
working and that they are ready and dialed in for the telehealth visit.
Consider the communication channels that
your patients might use and trust, including
those that aren’t social media or websites.
For example, you can get the word out
through emails/messages to community
organizations/coalitions, social service
organizations, and other trusted partners who
can help facilitate access on your behalf.
Coverage to Care Telehealth for Providers: What You Need to Know 10 11
If possible, have IT support available to assist if technology issues occur.
Make sure you have consent for the visit if needed. Each state has different
guidelines; some require paper documentation. Regardless of state laws, keep
in mind these best practices:
•
When you meet with a patient, explain what they can expect from the
telehealth visit and what their rights are.
•
Check in with the patient about their responsibilities during a telehealth
visit—for example, they need to be aware of privacy on their end.
•
If there is anyone observing the visit, tell the patient and get their consent
at the start.
•
Don’t record a visit.
Talking to patients about telehealth: Talking to your staff about telehealth:
Share the benets of telehealth relevant to them. For
Arrange a training with your software vendor and
example, explain how it reduces their exposure during
invite all relevant staff.
COVID-19, is more convenient, and saves time.
Help them identify the equipment they have available for
Hold a Q&A session with staff and create a list of
telehealth. Let them know that audio-only visits are available
technical FAQs for them to reference later.
(if you provide them).
Encourage staff to do “practice runs” and test out the
Explain how their personal information will be protected.
software.
Offer information to patients who may not be able to
Consider holding a patient interaction training, as
afford the cost of internet or phone services about other
positive interactions can look different via telehealth.
options or resources to help.
Encourage them to check with their health insurance about
how telehealth is being covered. If they are a Medicare
Be patient; learning how to use unfamiliar technology
beneciary, let them know that CMS has expanded
can take a lot of practice.
coverage of telehealth for Medicare beneciaries.
You may receive pushback from some patients who
aren’t interested in using telehealth. Listen to their
Provide additional training sessions and/or share
concerns and let them know telehealth may be an
informational resources regularly.
option if they change their mind.
Educate staff on the presence of security risks as well
as best practices for safe remote work and use of
mobile communications devices.
Step 3: Conduct a telehealth visit
At the beginning of the visit:
•
Go into a private room and put a sign on the door so no one enters
the room.
•
If the patient is new, introduce yourself and conrm the patient’s identity.
Have them show you their driver’s license or valid photo ID.
•
Discuss the purpose of the visit and let them know what to expect.
•
Obtain the patient’s consent to the purpose of the visit and their participation.
Chart this consent if needed.
•
Determine who is in the room with the patient. You can ask a family member
to step out of the room if needed.
•
Assure the patient that their information will be secure. Conrm that they
have the privacy they need.
•
Outline the session to let the patient know what to expect.
•
Discuss what to do if the patient loses connectivity. Get their phone number;
a phone call can be a good option if the patient can’t access the internet.
During the visit:
•
Obtain the patient’s health history if needed.
•
Maintain the same standard of care as an in-person visit. Telehealth takes
practice, and you’ll get more comfortable the more you do it.
•
Obtain as much clinical data as possible. If it is a video visit, try using creative
strategies in place of peripherals. For example, use household items like an
iPhone or Apple Watch to get information.
—
Explore your options for using peripherals for clinical assessment,
diagnostic testing, and clinical treatment at a distance. You may have
access to noninvasive peripherals like stethoscopes and invasive
peripherals like cystoscopy.
At the end of the visit:
•
Provide a plan for the patient, set up any referrals needed, and send notes to
the patient, just as you would after an in-person visit.
Coverage to Care Telehealth for Providers: What You Need to Know 12 13
Telehealth tips
How to set up for a
telehealth visit:
How to effectively
communicate during a
telehealth visit:
Ensure your lighting is correctly
placed. If possible, conduct
the visit with natural light in
front of you.
Eliminate background noise as
much as possible. Make sure
you’re muted when you aren’t
speaking.
Check your surroundings. Avoid
leaving anything behind you that
you wouldn’t want your patients
to see, especially personal
items. Ensure your space isn’t
cluttered.
Wear appropriate clothing that
you’d wear to an in-person visit.
If you normally would, wear a
lab coat and ensure your name
badge is visible if possible.
Avoid “primping” (looking at
yourself on the screen, xing
your hair, etc.).
Ensure your head placement is
in the center of the screen.
Maintain proper eye gaze. Look
at the area on your computer
between the camera and the
center of the screen.
Let the patient know when
you’re charting so they know
why you’re looking down.
Maintain a normal pace of
speech. Talk slowly enough that
the patient can understand you.
You may have to take longer
pauses than you would during
an in-person visit.
Use empathetic word choices
mindfully and nod your head so
the patient knows they’re being
heard and understood.
Ensure your facial expressions
and words are congruent.
When you’re listening quietly, be
aware of your resting face.
15Telehealth for Providers: What You Need to Know Coverage to Care 14
16
Considerations for various populations
Outlined below are considerations for people with disabilities, non-English-speaking patients, rural
populations, behavioral health, and additional tips for any patient. For more information on telehealth
equity and access, please visit the HHS telehealth website.
People with disabilities
Access to telehealth and telecommunications technology must be inclusive, especially for those patients
who may have disabilities that cause the use of technology and/or communication to be more challenging.
Section 504 of the Rehabilitation Act and the Americans with Disabilities Act protects qualied individuals
with disabilities from discrimination on the basis of disability in the provision of benets and services.
To provide these individuals with effective communications, covered providers must provide auxiliary
aids and services when needed. Providers should discuss what aid or service is most appropriate with
the person making the request.
Examples of aids and services your patient may need include:
For blind/vision-loss/deaf-blind patients — Providing a qualied reader; information in large print,
Braille, or electronically for use with a computer screen-reading program; or an audio recording of
printed information
For deaf/hearing-loss/deaf-blind patients — Providing a qualied notetaker, qualied sign language
interpreter, oral interpreter, cued-speech interpreter, tactile interpreter, real-time captioning, written
materials, or a printed script of a stock speech
For patients with speech disabilities — Providing a qualied speech-to-speech translator, or
suggesting the patient use paper/pencil to write out words; staff should listen attentively and not be
afraid to ask the patient to repeat a word or phrase they don’t understand
Per HHS Ofce for Civil Rights (OCR) Guidance, failure to ensure that services provided through
Electronic and Information Technology (EIT) are accessible to people with disabilities may constitute
discrimination under federal civil rights laws.
Coverage to Care Telehealth for Providers: What You Need to Know 17
Non-English-speaking patients
Providers should be aware of the unique challenges that non-English speakers face when
using telehealth.
•
Non-English speakers are far less likely to use portals than English speakers, due to a combination
of technology and language barriers. Consider whether a portal is required for these patients or
whether there is another way to connect with them.
See the PHE policy update section in this toolkit for a list of communications apps that are covered
during COVID-19.
•
To effectively communicate with non-English speakers, providers can conference a medical
interpreter into the call or video. Medical interpreters are specially trained in medical terminology,
patient privacy, and cultural awareness.
•
Remote interpreting companies contract medical interpreters. Some companies can give interpreters
direct access to a portal, so they can join the virtual room at the same time as the patient. Alternate
ways to bring in an interpreter include:
—
Securely sending the virtual room link to the interpreter
—
Keeping the provider and patient on video, with the interpreter on speaker phone
—
Holding a 3-way telephone call with the provider, patient, and interpreter (without video)
Telehealth for rural populations
Telehealth is especially critical in rural and other remote areas that lack sufcient health care services,
including specialty care. However, rural communities face specic barriers to implementing telehealth,
particularly limited access to high-speed internet and smartphones. Expanded broadband access is
needed to reduce health disparities for rural patients who could benet greatly from telehealth.
In response to this digital divide, federal, state, tribal, and territorial governments have developed
innovative strategies to improve telehealth access and utilization and decrease technical barriers.
For example:
•
The Federal Communications Commission Lifeline program provides monthly wireless and
broadband service discounts to people with low incomes.
•
Some states offer drive-in WiFi hotspots to provide free, temporary internet access to individuals
without home broadband access.
— Remind patients not to enter sensitive personal data while utilizing public WiFi.
— If feasible, give patients the option to drive to a designated location, such as your health care
clinic, to get reliable internet access and complete a telehealth visit in their car.
•
Some payers/insurers cover telephone visits as a replacement for video visits with similar
reimbursement rates. See Key Medicare changes at a glance and Audio-only visits for more
information on audio-only visits.
•
CMS issued an array of new rules and waivers of federal requirements to help the U.S. health care
system respond to the COVID-19 pandemic. See Rural health for a list of the exibilities that impact
rural providers.
Additionally, telehealth has successfully alleviated the lack of behavioral health services in many rural
communities. Consider how you can use telehealth to provide the following behavioral health services:
•
Evaluation and diagnosis – Use telehealth technology to observe the patient; administer scales,
assessments, and screenings; and diagnose conditions.
•
Case consultation – Consult with psychiatrists and psychologists by direct video communication,
telephone, or email.
•
Treatment – Provide counseling and psychotherapy. You may be able to offer more specialized
therapies such as medication-assisted therapy (MAT), cognitive processing therapy, or prolonged
exposure therapy for post-traumatic stress disorder (PTSD).
Coverage to Care Telehealth for Providers: What You Need to Know 18 19
•
Medication management – Help patients adhere to their medication regimens. Tools that rural
communities have used for medication adherence include monitored in-home dispensing devices,
mHealth apps, and telephone counseling.
•
Continuing care – Offer case management services through telehealth to improve patient
outcomes.
•
Provider education – Offer training or continuing education about behavioral telehealth through
distance learning, telementoring, or webinars.
Telehealth for all
How to address the digital divide: How to promote health equity:
Make it a priority.
Listen to groups with access challenges and
work with them to design interventions.
Connect patients to resources.
Advocate for better broadband.
Simplify the technology.
Develop patient-facing materials in multiple languages
and formats, including materials for the hearing and
visually impaired.
Consider the reading level of materials – seek input from
patient advocacy groups.
Provide opportunities for in-person support – utilize
medical assistants.
•
Do a dry run with patients the day before their
visit to reduce technological problems.
Ensure your video platform has interpreter services and
closed-captioning options built in and easy to use.
When evaluating a platform consider usability, reliability,
and privacy/security.
Telehealth for behavioral health
The stress of the COVID-19 pandemic has resulted in an increased demand for mental and behavioral
health services. Fortunately, telehealth has allowed many behavioral health providers to sustain and
even expand their services.
Teletherapy has been shown to benet both patients and providers in many ways, including:
•
Improving accessibility to mental health treatment
•
Reducing cancelled appointments and no-shows
•
Supporting patients who have difculty with daily tasks required for in-person visits
•
Helping patients avoid some of the stigma related to treatment
•
Assisting low-income patients who otherwise may have to sacrice work hours to attend
an appointment
However, there are also special considerations to account for when providing teletherapy:
•
Some patients don’t have a safe space to be completely themselves and not be overheard.
•
Physical presence can be a huge part of the therapeutic relationship.
•
It’s harder to read social and physical cues through a screen.
Teletherapy tips
•
Use video instead of audio-only whenever possible. Use the right equipment to ensure high-quality
video and audio.
•
Treat the session like an in-person appointment—turn off your phone, eliminate distractions, and give
it your whole focus.
•
Sit further back from the screen to see a wider area and better catch the slight facial expressions and
eye gestures of your patient.
•
Pay close attention to voice nuances, tempo, pitch, and inection. These can be equally as important
as the visual observations.
•
Need more information? Review SAMHSA’s treatment improvement protocol: Using Technology-
Based Therapeutic Tools in Behavioral Health Services.
Coverage to Care Telehealth for Providers: What You Need to Know 20 21
22
BILLING FOR TELEHEALTH
Billing and reimbursement requirements for telehealth
services vary among different payers/insurers and for
different geographic locations. Factors include:
•
Federal policies and regulations, including Medicare
•
State policies and regulations, including Medicaid and
commercial insurers
Current policies, regulations, and requirements are evolving
and subject to change:
•
Many are temporary and in effect only during the COVID-19 PHE.
•
Some changes in response to the PHE have been extended or
made permanent.
•
Information presented here is current as of May 2023.
•
If you are unsure about coverage or have questions about
particular plans, you may wish to contact the insurance carrier
to ensure what types of telehealth they cover and if the telehealth
service your patient needs is a covered benet.
Coverage to Care Telehealth for Providers: What You Need to Know 23
Federal policies: Medicare
The federal government announced a series of policy changes that broadened Medicare coverage and
payment for telehealth services during the COVID-19 PHE.
The COVID-19 PHE ended on May 11, 2023, but the Consolidated Appropriations Act, 2023, extended
many telehealth exibilities through December 31, 2024, such as:
•
People with Medicare can access telehealth services in any geographic area in the United States,
rather than only in rural areas.
•
People with Medicare can stay in their homes for telehealth visits that Medicare pays for rather than
traveling to a health care facility.
•
Certain telehealth visits can be delivered using audio-only technology (such as a telephone) if
someone is unable to use both audio and video (such as a smartphone or computer).
Please view the Telehealth Changes after the COVID-19 PHE web page for more on permanent
Medicare changes, temporary changes through December 31, 2024, and telehealth exibilities that end
after May 11, 2023.
Resources and Background. The following are important resources about billing, coverage, and
payment, as well as information on the PHE, waivers and exibilities, and nal rules:
•
Billing and Reimbursement
•
Medicare T elemedicine Fact Sheet
•
Medicare Telehealth FAQs
•
List of Medicare Telehealth Services
•
Medicare Fee-For-Service Response to the PHE on COVID-19
•
CMS COVID-19 Updates
Medicare began paying for virtual check-ins in 2019. Virtual check-ins are brief phone calls or
video chats to see whether patients need to make an ofce visit.
Medicare policies in place during the COVID-19 PHE expanded payment for telehealth. HHS
determined on January 31, 2020 that a PHE exists and has existed since January 27, 2020. Using
emergency authorities enacted by Congress for the PHE, CMS announced a number of temporary
waivers of statutory telehealth payment requirements. CMS also issued an array of temporary regulatory
exibilities for Medicare telehealth services during the COVID-19 PHE. Many of these exibilities will
remain through December 31, 2024.
Effective March 1, 2020, Medicare began paying for a wide range of telehealth services
in response to the PHE. These services include:
•
Emergency department visits
•
Initial inpatient and nursing facility visits
•
Discharge day management services
•
Certain services delivered to patients who are at home
For calendar year 2021, CMS nalized the addition of the following services to the Medicare
telehealth list, which remain covered after the end of the PHE on May 11, 2023:
•
Group psychotherapy
•
Psychological and neuropsychological testing
•
Lower-level domiciliary, rest home, or custodial care services, established patients
•
Lower-level home visits, established patients
•
Cognitive assessment and care planning services
•
Visit complexity inherent to certain ofce/outpatient evaluation and management (E/M)
•
Prolonged services
CMS also added a number of services to the Medicare telehealth list on a temporary (category 3)
basis, meaning they will remain on the list through calendar year 2023. CMS will continue considering
requests to add services to the list of covered Medicare telehealth services, so check the Medicare
telehealth services page for the most current list.
Under the COVID-19 PHE, Medicare Advantage plans covered all telehealth services covered under
Medicare fee-for-service. CMS also exercised enforcement discretion during the PHE to allow Medicare
Advantage plans to expand coverage of telehealth services. Medicare Advantage plans aren’t required
to expand covered services but have the exibility to do so. After December 31, 2024, when these
exibilities end, some Accountable Care Organizations may offer telehealth services that allow for
primary care doctors to care for patients without an in-person visit, no matter where they live.
Key Medicare changes at a glance
Requirement Type Pre-COVID-19 PHE Policy COVID-19 PHE Policy*
Patient site/geographic location
Services
Telehealth modality
Provider type
Payment available only for care at
certain facility types with limited
services for home-based patients
Patient location must be rural or
outside a metropolitan statistical
area (MSA)
Payment available for about 90
services, as captured by
CPT/HCPCS codes
Payment for live video only, except
for certain demonstration projects in
Alaska and Hawaii
Payment available for services
furnished by limited list of 9
provider types
No restrictions on
geographic location
Patients can be at home or any
other setting
Payment available for about 250
services, as captured by CPT/
HCPCS codes, as of February 2023
Payment available for live video,
with audio-only phone for E/M
services, behavioral health
counseling, and educational services
Payment available for all health care
professionals who are eligible to bill
Medicare for professional services
*The COVID-19 PHE ended on May 11, 2023. However, these exibilities have been extended through December 31, 2024.
Coverage to Care Telehealth for Providers: What You Need to Know 24 25
Rural health
The Rural Crosswalk: CMS Flexibilities to Fight COVID-19 outlines provisions that CMS has
issued by regulation or waiver that impact:
•
Rural health clinics
•
Federally Qualied Health Centers
•
Critical Access Hospitals
•
Rural acute care PPS hospitals
•
Skilled nursing facilities
Audio-only visits
CMS issued a waiver to allow the use of audio-only equipment to furnish services
described by the codes for audio-only telephone E/M services, behavioral health counseling, and
educational services. This waiver is in effect until December 31, 2024.
Effective January 1, 2021, CMS established payment on an interim nal basis for a new HCPCS G-code
describing 11-20 minutes of medical discussion to determine the necessity of an in-person visit.
See the full list of telehealth services eligible to be furnished via audio-only technology, including the
telephone E/M codes.
State policies: Medicaid
States have broad exibility to cover Medicaid services when they are delivered via telehealth, including by
telephone, video conferencing, and other methods of communication. Medicaid telehealth policy differs
from state to state. Most states have expanded coverage for Medicaid services delivered via telehealth
during the COVID-19 PHE. For instance, many states are now covering:
•
Services delivered via telephone, electronic, and virtual means
•
Home as the originating site for telehealth
•
Coverage and pay parity for services delivered via telehealth
Use the following resources to learn more about coverage of Medicaid services delivered via telehealth:
•
COVID-19 FAQs for State Medicaid and CHIP Agencies
•
General Telehealth Page on Medicaid.gov
•
Medicaid State Plan Fee-for-Service Payments for Services Delivered Via Telehealth
•
State Medicaid & CHIP Telehealth Toolkit and Supplement
As of September 2022, Medicaid fee-for-service offers reimbursement for select modalities:
•
Live video in 50 states and the District of Columbia
•
Remote patient monitoring in 34 states
•
Store-and-forward in 25 states
Like Medicare, Medicaid policies have been adjusted during the COVID-19 PHE.
For detailed information, review the State Medicaid & CHIP Telehealth Toolkit. Medicaid changes vary by
state and may include payment for:
•
Audio-only phone visits
•
Services furnished to homebound patients
•
Expanded list of provider types
•
Expanded list of services
As with Medicaid fee-for-service, coverage of services delivered via telehealth under Medicaid managed
care will vary from state to state. Some states require Medicaid managed care organizations to align
their coverage of services delivered via telehealth with coverage for these services under Medicaid
fee-for-service. CMS encourages states to amend managed care contracts (if telehealth is not already
addressed in the contract) to extend the same telehealth exibilities authorized under their state plan,
waiver, or demonstration to services covered under the managed care contract.
CMS encourages both state Medicaid programs and private insurers to cover a robust variety of
services when they are delivered via telehealth. And many states require commercial insurers to cover
services delivered via telehealth. Several large insurers have expanded coverage of services delivered
via telehealth.
Coverage to Care Telehealth for Providers: What You Need to Know 26 27
Documentation and coding tips
As for all professional services, timely and correct payment for telehealth depends on complete and
accurate documentation and coding, whether for government or private payers.
Documentation of your patients’ diagnoses and the services you furnished allows for the proper
selection of diagnosis and procedure codes. These codes are in turn used to determine payment.
Best practices and tips for documentation and coding include:
•
Work closely with your administrative staff—for example, your practice manager or biller—
to understand documentation and coding requirements.
•
Complete documentation at the time of service.
•
Document the amount of time you spent providing the service.
•
Document and code for place of service (POS).
— For Medicaid, reach out to your state agency.
— For private insurers, POS code requirements vary.
•
Verify that your documentation supports the codes used.
For Medicare:
•
Use the POS code you would’ve used if the service was provided in person.
•
Use the CPT modier 95 for telehealth services provided in real-time.
Before submitting a Medicare claim, verify that the service provided is included on the list of available
codes for telehealth.
ADDITIONAL RESOURCES FOR
PROVIDERS AND PARTNERS
•
HHS Telehealth Website
•
Coverage to Care (C2C) Website
•
C2C Consumer-Facing Resource “Telehealth: What to Know for Your Family”
•
Agency for Healthcare Research and Quality Resources
•
Billing and Reimbursement for Telehealth
•
HIPAA Flexibility for Telehealth Technology
•
OIG Cost-Sharing Waiver Policy Statement and FAQs
•
Medicare Telemedicine Fact Sheet
•
Medicare Telehealth FAQs
•
List of Medicare Telehealth Services
•
Medicare Fee-For-Service Response to the PHE on COVID-19
•
CMS COVID-19 Updates
•
COVID-19 FAQs for State Medicaid and CHIP Agencies
•
General Telehealth Page on Medicaid.gov
•
Medicaid State Plan Fee-for-Service Payments for Services Delivered Via Telehealth
•
State Medicaid & CHIP Telehealth Toolkit and Supplement
•
Requirements and Best Practices for Assisters on Providing Remote Consumer Assistance
•
HHS Telehealth for Community-Based Organizations Webinar Series
•
Rural Crosswalk: CMS Flexibilities to Fight COVID-19
•
Rural Health Info (RHI) Rural Telehealth Toolkit
•
Health Resources & Services Administration (HRSA) Telehealth Information
•
HRSA Telehealth Resource Center
•
HRSA Rural FQHC Telebehavioral Health Guidelines
•
Substance Abuse and Mental Health Services Administration (SAMHSA) COVID-19 Resources
•
SAMHSA Telehealth Information for Certied Community Behavioral Health Clinics
Technical assistance
CMS OMH offers Health Equity Technical Assistance for health care organizations that are working
to advance health equity. For help or more information about working with vulnerable populations,
visit our website at go.cms.gov/OMH or email the Health Equity Technical Assistance program at
HealthEquityT[email protected].
Coverage to Care Telehealth for Providers: What You Need to Know 28 29
go.cms.gov/c2c
Paid for by the U.S. Department of Health and Human Services
Revision Date: May 2023
Publication # 12121
The contents of this document do not have the force and effect
of law and are not meant to bind the public in any way, unless
specically incorporated into a contract. This document is
intended only to provide clarity to the public regarding existing
requirements under the law.
