Coding Telehealth Services

Documents Required

• Encounter note documenting the telehealth service (same documentation standards as in-person)
• Technology/platform documentation (audio-video vs. audio-only)
• Patient consent for telehealth (required by most states and Medicare)
• Patient location documentation (state and setting)
• Provider location and licensure in the patient's state
• CMS Telehealth Eligible Services List (current calendar year)
• Payer-specific telehealth policies

Step 1 — Determine the Service Category

Classify the telehealth service type — each has different coding rules.

Synchronous audio-video telehealth:

• Real-time interactive audio and video communication between patient and provider.
• Uses the same CPT/HCPCS codes as in-person services (E/M, psychotherapy, consultations, etc.).
• Must be on the CMS Telehealth Eligible Services List for Medicare reimbursement.
• Requires interactive audio AND video — audio-only does not qualify (with limited exceptions).

Audio-only services:

• 99441: 5–10 minutes of medical discussion (telephone E/M).
• 99442: 11–20 minutes.
• 99443: 21–30 minutes.
• Medicare allows audio-only for certain behavioral health services (90832–90838, 90839, 90845) and E/M services in limited circumstances for established patients.
• Audio-only eligibility varies significantly by payer and state.

Remote evaluation and management:

• G2010: Remote evaluation of recorded video/images submitted by an established patient (store-and-forward). Not a real-time service.
• G2012: Virtual check-in — brief communication (5–10 minutes) via synchronous technology initiated by an established patient. Not a separately billable E/M.
• 99421–99423: Online digital E/M service (patient portal communication over 7-day period). Time-based: 5–10 min, 11–20 min, 21+ min cumulative.

Remote Patient Monitoring (RPM):

• 99453: Initial setup and patient education on RPM devices (one-time).
• 99454: Device supply with daily recording and programmatic alerts, per 30 days.
• 99457: RPM treatment management, first 20 minutes per calendar month.
• +99458: Each additional 20 minutes per calendar month.
• 99091: Collection and interpretation of physiologic data, 30+ minutes per 30 days (cannot bill with 99457 in the same month).

Step 2 — Select the Correct Place of Service

POS determines payment rates and modifier requirements.

Medicare POS rules (post-PHE permanent policy):

• POS 02 — Telehealth provided other than in patient's home: Patient is at an originating site (clinic, hospital, SNF, etc.). Facility rate applies.
• POS 10 — Telehealth provided in patient's home: Patient is at home. Non-facility rate applies.
• When the patient is at home, use POS 10. When at a healthcare facility, use POS 02.
• For audio-only services, use POS 02 or 10 based on patient location.

Commercial payer POS rules:

• Some commercial payers require the original POS (11 for office, 22 for hospital outpatient) with modifier 95 to indicate telehealth.
• Others use POS 02/10 following the Medicare model.
• Check payer-specific policy before claim submission.

Originating site requirements (Medicare):

• For services still subject to geographic restrictions, the originating site must be in a rural HPSA or non-MSA county.
• Mental health and behavioral health telehealth services were permanently exempted from geographic restrictions (effective 2025).
• An originating site facility fee (Q3014) can be billed by the facility where the patient is located (not the distant site provider).

Step 3 — Apply Telehealth Modifiers

Select the correct modifier based on service type and payer.

• Modifier 95: Synchronous telehealth service via real-time audio and video. CMS-preferred modifier for Medicare claims. Applied to the procedure code on the professional claim.
• Modifier GT: Telehealth via interactive audio and video telecommunications system. Used by some commercial payers instead of or in addition to modifier 95.
• Modifier FQ: Telehealth service provided using audio-only communication technology. Required by Medicare for eligible audio-only services.
• Modifier FR: Supervising practitioner present through real-time audio-video communication technology for services furnished by a resident. Used in teaching physician scenarios.
• Modifier G0: Telehealth service for diagnosis, evaluation, or treatment of symptoms of an acute stroke. Applied to acute stroke telehealth consultations.
• Modifier 93: Audio-only services (used by some state Medicaid programs instead of FQ).

Key modifier rules:

• Do NOT append telehealth modifiers to RPM codes (99453–99458) — RPM is not a telehealth service.
• Do NOT append telehealth modifiers to virtual check-ins (G2010, G2012) or e-visits (99421–99423).
• Medicare requires modifier 95 for all telehealth-eligible CPT codes and modifier FQ for audio-only eligible services.

Step 4 — Validate Medicare Telehealth Eligibility

Confirm the service is on the CMS Telehealth Eligible Services List.

• CMS publishes an updated list annually (effective January 1) with additions from the Medicare Physician Fee Schedule Final Rule.
• Services on the list include: office/outpatient E/M (99202–99215), subsequent hospital care (99231–99233), psychiatric services (90791–90899), certain consultation codes (not recognized by Medicare FFS but relevant for MA plans), and specific procedure codes.
• Services NOT on the list cannot be billed as Medicare telehealth — they must be provided in-person.
• Some services were added temporarily during the PHE and may not be permanent — verify against the current list.
• Medicare Advantage plans may cover additional telehealth services beyond the FFS list — check the MA plan's supplemental benefits.

Step 5 — Code Remote Patient Monitoring

Apply RPM coding rules for chronic condition monitoring.

• Eligibility: Patient must have a chronic condition requiring monitoring (e.g., hypertension, diabetes, CHF, COPD).
• Minimum data requirement: RPM requires at least 16 days of data collection within a 30-day period for 99454 to be billable.
• 99453 (initial setup): One-time code for setting up the RPM device and educating the patient. Billed once per episode of care.
• 99454 (device supply/data transmission): Billed per 30-day period. Requires daily recording or programmatic alerts.
• 99457 (treatment management): Requires at least 20 minutes of clinical staff time per calendar month interacting with the patient about the RPM data. Must include live interaction (phone, video, or in-person).
• +99458 (additional time): Each additional 20-minute increment beyond the first 20 minutes.
• RPM can be furnished by clinical staff under general supervision of the billing provider.
• RPM is NOT telehealth — it does not require real-time audio-video and is not subject to telehealth POS/modifier rules.

Checkpoint B — Review

• Service category correctly identified (synchronous A/V, audio-only, RPM, virtual check-in, e-visit)
• CPT/HCPCS code is on the CMS Telehealth Eligible Services List (for Medicare claims)
• Place of service matches patient location (POS 02 vs. POS 10 vs. original POS per payer)
• Correct telehealth modifier applied (95, GT, FQ, FR, G0) per payer requirements
• Audio-only services are limited to eligible codes with proper modifier FQ
• RPM codes are NOT modified with telehealth modifiers
• Patient consent for telehealth is documented
• Provider licensure in the patient's state is verified

Quality Audit

• Telehealth claims use the correct POS for the payer (not defaulting to POS 11 for all telehealth)
• Audio-only vs. audio-video service type matches documentation and applied modifiers
• RPM data collection meets the 16-day minimum per 30-day period for 99454
• RPM treatment management (99457) includes documented live patient interaction
• Telehealth consent documentation is present for every telehealth encounter
• State telehealth parity law requirements are met for commercial payer claims
• Originating site fees (Q3014) are billed only when the patient is at an eligible originating site

Guidelines

• Follow CMS Telehealth Eligible Services List (updated annually in the Medicare Physician Fee Schedule Final Rule)
• Apply CMS Medicare Claims Processing Manual Chapter 12 §190 for telehealth billing requirements
• Reference CMS MLN Matters articles for telehealth policy updates and clarifications
• Follow state telehealth parity laws for commercial payer coverage requirements
• Apply HIPAA security requirements for telehealth technology platforms
• Never bill a telehealth service as an in-person visit without telehealth modifiers — this misrepresents the service
• Mark with [VERIFY] any telehealth service where eligibility, POS, or modifier selection is uncertain
• Include disclaimer that telehealth coding rules change frequently and payer-specific policies must be verified at the time of billing