The Centers for Medicare & Medicaid Services (CMS) recently changed telehealth billing during COVID-19. CMS also waived certain telehealth rules with the goal of expanding patient access to healthcare while remaining at home.

Telehealth billing during COVID-19

As a physician this is a great time to brush up on telehealth billing. Let’s look at four types of telehealth visits providers can bill for, including key changes and considerations during COVID-19. We’ll cover telehealth, virtual check-ins, e-visits, and remote patient monitoring.


Telehealth can be used to care for new and established patients with the same services provided during in-person visits. These include outpatient clinic, inpatient, nursing facility, and therapy visits.

However, CMS recently expanded access to telehealth in a few important ways. While before COVID-19 only specific types of practitioners could bill for telehealth, all practitioners are now eligible to bill Medicare for the duration of the emergency.

This means physical and occupational therapists as well as speech language pathologists can now use telehealth to provide Medicare services. It also allows clinicians to provide emergency department visits, critical care services, group psychotherapy, and many other types of care not previously billable as telehealth.

Providers can bill telehealth visits at the same rate as in-person visits. However, you can waive Medicare copayments for telehealth beneficiaries. This means you would only be reimbursed for the portion Medicare pays (80% of the allowable).

You should review CPT and CMS documentation guidelines to choose the appropriate CPT code for billing. CMS says to bill non-traditional telehealth visits conducted after March 1, 2020 using the same Place of Service (POS) code you would have used in normal circumstances. Use modifier 95 to indicate a service you performed via telehealth.

Visit for a full list of services that can be provided via telehealth during the COVID-19 pandemic.

Visit for a full list of payable telehealth services during COVID-19

Virtual check-ins

A “virtual check-in” pays professionals for brief (5-10 min) communications that mitigate the need for an in-person visit. These are different from Medicare telehealth, which is treated the same as an in-person visit and can be billed using the code for that service.

Virtual check-ins can be provided via telephone, audio/video message, secure text messaging, email, or use of a patient portal. They can also include captured video or images sent to a provider and responded to at a later time.

Importantly, virtual check-ins cannot be related to an E/M service provided in the past seven days (or leading to a visit in the next 24 hours).

Bill virtual check-ins with HCPCS code G2010. Alternatively, use G2012 to bill for time spent remotely evaluating recorded video or images submitted by the patient.

For time-based telephone and E/M services, use CPT codes 99441 or 99443. Other clinicians – including licensed clinical social workers, psychologists, physical therapists, occupational therapists, and speech language pathologists – can use codes 98966 and 98968 for virtual check-ins.

As with E-visits and remote patient monitoring (discussed below), you can bill virtual check-ins for both new and established patients. These services were previously limited to established patients.


“E-visits” refers to digital management services conducted through a patient portal. There are two sets of codes for these services depending on provider type. Bill virtual E/M services with codes 99421 to 99423 depending on total time spent on the visit over seven days.

For other clinicians, use codes G2061 to G2063.

Remote patient monitoring (RPM)

During COVID-19, clinicians can provide RPM services to new and established patients for both acute and chronic conditions. For example, you could bill for RPM if you were monitoring a patient’s oxygen saturation levels using pulse oximetry.

For RPM you would select from the following CPT codes: 99091, 99457 to 99458, 99473 to 99474, and 99493 to 99494.

Check your state requirements

Note that billing differs by state, so it’s important to check your state requirements for telehealth billing during COVID-19.

The Federation of State Medical Boards (FSMB) publishes updates on states modifying requirements for telehealth in response to COVID-19. Check for the latest FSMB update for guidance on your specific state requirements.

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