The Provider’s Guide to Billing for Telehealth
Offering virtual visits is a fantastic way to expand patient access, but it only works if your practice gets paid for the services you provide. Unfortunately, the unique requirements for billing for telehealth create new opportunities for revenue leakage. A simple mistake, like using modifier 95 for an audio-only call or forgetting to document patient consent, can result in a denied claim. These small errors add up, impacting your cash flow and bottom line. To protect your practice’s financial health, you need a solid grasp of the rules. Here, we’ll cover the critical details of telehealth coding and documentation to ensure you capture every dollar you’ve earned.
As shelter in place orders begin to lift in cities and states throughout America, there is more of a spotlight on the medical community than ever before. The spread of COVID-19 and its effect on healthcare systems means that now, more than ever, doctors, nurses and physician assistants must focus on their patients’ health and well-being, instead of operational tasks like billing and coding.
Outsourcing the revenue cycle management process for your practice is time and money well spent. However, it’s crucial you work with a company that knows what it’s doing. Here at Med USA, we have more than four decades of experience in the medical billing field. Our team of highly-trained experts knows exactly what it takes to speed up the billing process, ensuring revenue continues to flow.
With fewer and fewer people visiting the doctor in person, it’s also important that you implement telemedicine at your practice. Telemedicine ensures your most vulnerable patients receive the care they need without unnecessary exposure to illness in your waiting room or medical facility. Unfortunately, there’s some complexity regarding telemedicine reimbursement. Both commercial payers and CMS have been slow to enact policies around telemedicine reimbursement. But COVID-19 has made that a priority.
The Rise of New Medical Codes for COVID-19
Did you know that some states and payers reimburse for telehealth at the same rate as in-person visits? Or that you can provide telehealth services no matter where a patient is located geographically? If not, you aren’t alone. These are two of several developments that have occurred due to the COVID-19 pandemic. In the past, telemedicine was coded and billed differently than an in-person visit. If you were working with an inexperienced company, this could lead to errors on a claim and potentially a denial of payment from an insurance company. When you partner with Med USA, there’s nothing to worry about. Our experienced billers are well aware of the new telemedicine mandates and know exactly what it takes to file claims exactly as required. This means less stress for you. It also means you can focus more on your patients. Each type of medical visit requires a unique billing process. Once a billing department determines the guidelines from a particular insurance company, they’re then required to find the right CPT code. These codes were traditionally used. for office and outpatient visits, but they can now be utilized for telemedicine visits as well. Coverage for telemedicine services depends on a patients’ insurance policy. This means billers must be aware of specific codes when filing payments.
Understanding Different Types of Virtual Care
Before you can bill for a virtual visit, you need to know exactly what kind of service you provided. Telehealth isn’t a one-size-fits-all term; it covers a range of digital healthcare services, each with its own set of rules and codes. Getting this right from the start is the first step to ensuring proper reimbursement. It’s about matching the patient interaction to the correct service category, which can feel like a puzzle. But once you understand the key distinctions, you can build a clear process for your practice that prevents confusion and claim denials down the line.
Synchronous vs. Asynchronous Telehealth
The main way to categorize telehealth is by whether it happens in real-time. Synchronous telehealth is what most people picture: a live, two-way conversation using both video and audio. As the Colorado Department of Health Care Policy and Financing puts it, “Telemedicine is a way to give healthcare services using live video and audio. It’s not a new type of service, but a different way to deliver services that are already approved.” This is essentially a virtual face-to-face appointment. Asynchronous telehealth, or “store-and-forward,” is when you share medical information—like images or messages—through a secure platform for the provider to review later. Both are valuable, but they are billed very differently, making accurate medical billing essential.
e-Visits, Virtual Check-ins, and Remote Patient Monitoring (RPM)
Beyond the basic categories, there are more specific types of virtual care. E-visits are patient-initiated conversations through a secure online portal, often for established patients. According to the AAFP, these are coded based on time over a seven-day period, with codes like 99421 for 5-10 minutes of communication. Virtual check-ins are brief, patient-initiated calls to decide if an office visit is needed. Remote Patient Monitoring (RPM) involves collecting and analyzing patient health data from a distance, like blood pressure or glucose levels. Each of these services has unique coding and billing requirements that must be followed precisely to ensure payment.
Documentation, Consent, and Compliance
Just like an in-person visit, virtual care requires meticulous documentation and adherence to strict compliance standards. In fact, the rules can be even more specific for telehealth. From getting the right kind of consent to using secure technology, every step needs to be handled correctly to protect your patients and your practice. This isn’t just about getting paid; it’s about maintaining patient trust and meeting legal obligations. A solid revenue cycle administration process will have these compliance checks built-in, so nothing falls through the cracks.
Obtaining and Documenting Patient Consent
You can’t just start a video call; you need documented consent first. The requirements can vary, but a common guideline is that “for the first telemedicine visit, providers must give the patient written statements to sign.” For any follow-up virtual visits, “verbal or written consent from the patient is okay.” It’s critical to document this consent in the patient’s record every single time. This step is a prerequisite for billing and a fundamental part of patient rights. Skipping it can lead to denied claims and potential compliance issues, so make it a mandatory part of your telehealth workflow.
Using HIPAA-Compliant Technology
Patient privacy is paramount, and the technology you use must reflect that. Standard video chat platforms aren’t secure enough for healthcare. All virtual services must follow strict privacy rules like HIPAA to protect sensitive patient information. This means that any “transmissions must be secure and encrypted.” Choosing a HIPAA-compliant telehealth platform is non-negotiable. This ensures that your virtual waiting room is just as private as your physical one, safeguarding patient data and keeping your practice compliant with federal regulations.
Provider and Service Eligibility
Not every provider can bill for every telehealth service, and not every service is covered. Payer policies dictate who can provide virtual care and what specific services are reimbursable. This is one of the most complex areas of telehealth billing because the rules can differ between Medicare, Medicaid, and commercial insurance plans. Staying on top of these policies is a full-time job, which is why many practices partner with experts who handle provider credentialing and stay current on payer-specific guidelines to ensure claims are processed correctly.
Eligible Providers for Telehealth Billing
Generally, if a provider is licensed to deliver a service in person, they are often eligible to provide it via telehealth. CMS states that a wide range of healthcare professionals, including “physicians, PAs, NPs, clinical psychologists, and social workers can bill for these services.” However, it’s always important to verify eligibility with each specific payer, as some may have restrictions based on provider type or specialty. Ensuring your providers are properly credentialed for telehealth with each insurance plan is a crucial step before you begin offering virtual appointments.
Commonly Covered vs. Non-Covered Services
The golden rule for telehealth coverage is that services must be medically necessary and appropriate for virtual delivery. A service is typically covered if it is “already covered by Health First Colorado, are within the provider’s license, and can be properly given through telemedicine.” This includes many evaluation and management visits, mental health counseling, and chronic care management. However, services that require physical touch or in-person procedures are obviously not covered. Always verify coverage for a specific CPT code with the patient’s insurer before the visit to avoid billing surprises.
CPT codes and Medicare
While selecting and documenting the correct CPT codes is vital, there is an additional facet to be aware of –– Medicare billing. In most cases, services provided to Medicare patients require the addition of a modifier at the end of a specific CPT code. The modifier depends on the type of telecommunication technology used for the visit, whether video chat or strictly over the phone.
Standard Office and Outpatient Visit Codes (99202–99215)
One of the most significant changes in telehealth billing is the use of standard CPT codes for virtual visits. For office visits conducted via both audio and video, you can now use the same codes you would for an in-person appointment, specifically CPT codes 99202-99215. This shift simplifies the process, allowing you to bill for a telehealth encounter based on the level of service provided, just as you would if the patient were in your office. Keeping track of these evolving guidelines is essential for accurate reimbursement. Partnering with a dedicated medical billing service ensures your practice stays current, applying the correct codes and modifiers to prevent claim denials and maintain a healthy revenue stream.
Codes for e-Visits and Virtual Check-ins (99421-99423, 98016, G2252)
Not all virtual care fits the mold of a standard office visit. For patient-initiated digital communication, or “e-Visits,” with established patients, a different set of codes applies. These are time-based: 99421 for 5-10 minutes of communication, 99422 for 11-20 minutes, and 99423 for 21 minutes or more, all covering a seven-day period. Similarly, brief virtual check-ins (G2252) have their own specific coding rules. These codes are crucial for getting reimbursed for the time you spend communicating with patients outside of a formal appointment, a common practice in specialties like behavioral health. Properly documenting and coding these interactions is key to capturing all earned revenue.
Codes for Provider-to-Provider eConsults (99451, 99452)
Telehealth also extends to consultations between providers. When you consult with another physician electronically to coordinate patient care, you can bill for your time using specific eConsult codes. The treating practitioner typically uses CPT code 99452. It’s important to note that the date of service is the day you complete the consult, not when it was initiated. There’s also a critical rule to remember: you cannot bill for an eConsult separately if it takes place on the same day as a face-to-face visit with the patient. These nuances highlight the complexity of the healthcare revenue cycle and demonstrate why having an expert team managing your claims is so valuable for compliance and financial health.
Other Code Modifiers to be Aware of
Medicare services aren’t the only ones that require modifiers for proper reimbursement. Private payers have different modifiers based on the type of telecommunication technology used and CMS claims require the use of a “place of service” code. If you aren’t an experienced medical coder, these modifiers can be incredibly difficult to understand. Plus, one wrong code can mean waiting for weeks or months to receive payment. Without prompt payment, you lose income, and running a medical practice without cashflow just isn’t possible.
Required Place of Service (POS) Codes: 02 and 10
When submitting a claim for a telehealth visit, you must specify where the patient was located during the appointment. This is done using a Place of Service, or POS, code. For telehealth, the two primary codes you’ll use are POS 02 and POS 10. Use POS 02 when the patient receives telehealth services at a location other than their home, such as their workplace or a specialist’s office. If the patient is at home during the virtual visit, you’ll use POS 10. Getting this detail right is fundamental for a clean claim, as it directly impacts how payers process the reimbursement. It’s a small detail that can cause big delays if overlooked.
Key Modifiers for Virtual Care: 95 and 93
Modifiers provide extra information about a service, and for telehealth, they are essential. The most common modifier is 95, which you’ll append to a CPT code to show the service was delivered via a real-time, interactive audio and video connection. Think of a standard video call with your patient. However, if the service was conducted using only a telephone or another audio-only device, you must use modifier 93 instead. Differentiating between these two scenarios is critical for compliance and proper payment. This level of detail is where an expert medical billing team can prevent simple mistakes from turning into denied claims.
Other Modifiers (FQ, GT)
Beyond the primary modifiers, a few others apply in specific situations. For instance, modifier FQ is used for services provided via real-time audio-only communication, which can sometimes overlap with modifier 93 depending on payer rules. Another important one is modifier GT, which is specifically used by Critical Access Hospitals when they bill for telehealth services to indicate the use of interactive audio and video. These specific use cases demonstrate how nuanced telehealth coding can be. Staying current with these payer-specific requirements is a full-time job, which is why many practices rely on a dedicated revenue cycle management partner to handle the complexities.
Billing the Originating Site Fee (Q3014)
In some telehealth scenarios, the patient might be at a local clinic (the “originating site”) to connect with a specialist remotely. This originating site can bill a facility fee for providing the space and equipment for the virtual visit. The specific code for this is HCPCS code Q3014. This fee is billed by the facility where the patient is located, not the provider conducting the consultation. It’s a distinct charge that compensates the originating site for their role in facilitating the telehealth service. Understanding who bills for what is key to ensuring every party involved is compensated correctly and avoids duplicate or incorrect billing.
Guidelines for Billing Audio-Only Visits
Audio-only visits have become a vital way to provide care, but they come with their own set of billing rules. For Medicare patients, you can often use the standard office and outpatient E/M CPT codes (99202-99215) for audio-only calls, the same ones used for in-person and video visits. However, documentation is absolutely crucial. Payers need to see clear proof that an audio-only visit was not only medically necessary but also the patient’s preferred or only available method of communication at that time. This ensures you can defend the claim during an audit and secure proper reimbursement for the care you provide.
Documenting Patient Choice for Audio-Only
When billing for an audio-only visit, your documentation must be precise. If you had video technology available but the patient either chose not to use it or was unable to, you need to note that in their record. A simple statement like, “Video telehealth was offered, but the patient elected to proceed with an audio-only visit,” can make all the difference. This documentation justifies why a lower-tech option was used and demonstrates that you are meeting patient needs while adhering to payer guidelines. This simple step protects your practice and ensures the claim is processed smoothly without unnecessary questions or denials from the insurance company.
Coding Changes for Telephone Visits
The rules for telehealth are constantly evolving, and it’s important to stay informed about future changes. For example, significant updates are on the horizon for how audio-only visits are coded, particularly for mental and behavioral health services. As policies shift, your practice will need to adapt its billing processes to remain compliant and maintain a healthy revenue stream. Keeping up with these regulatory changes is a core function of our work at Med USA. We ensure our partners are always ahead of the curve, so they can focus on patient care without worrying about falling behind on the latest coding requirements.
Choosing a Qualified Billing Partner
The last few months have changed the world of medicine significantly. Now, more than ever, it’s important you know how to code and bill telemedicine services correctly. Feeling stressed? It’s okay! To assist you in the transition, we’ve created a helpful guide to telemedicine billing. Once you’re finished reading it, you’ll have a much better idea of what steps to take next. With more than four decades of building profitable relationships, our services are based on the concept of adaptability. We provide solutions for office-based physician practices, hospital-based practices and medical billing companies with services that are easy to implement and use. In addition, we provide scalable solutions for all types of providers, from small practices to large healthcare systems. We aren’t just puffing ourselves up, either. Over three case studies performed on practices and health organizations of varying sizes, Med USA reduced time in accounts receivable by nearly 40%. In addition, one study showed 94% of charts closed on the same day, while another showed 98% of cases were billed within 24 hours. If you need to partner with a medical billing and practice management company that you can trust, you’ve come to the right place. Our team provides a variety of customized solutions including an integrated electronic health record (EHR) system, medical coding and credentialing services. Get in touch with us today and find out more about how we can work together and help your revenues increase.
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Frequently Asked Questions
What’s the most common mistake practices make when billing for telehealth? One of the most frequent errors we see is a mismatch between the service provided and the codes used. For example, using modifier 95 (for audio and video) on a claim for an audio-only call is a quick way to get a denial. Similarly, using the wrong Place of Service (POS) code, like indicating the patient is in a clinic when they are actually at home, will also cause problems. These small details are critical for clean claims.
Can I just use a standard video chat app for virtual visits, or do I need special software? You absolutely need to use a HIPAA-compliant platform. Standard video chat applications don’t offer the necessary security and encryption to protect sensitive patient health information. Using a secure platform is non-negotiable for protecting patient privacy, meeting your legal obligations, and building trust with the people you care for.
How is billing for a quick phone call different from a full video appointment? They are billed as entirely different types of services. A full video appointment often uses the same evaluation and management codes as an in-person visit, just with a telehealth modifier. A brief phone call, however, falls into a category like “virtual check-ins,” which has its own unique set of codes. It’s essential to distinguish between these interactions to bill correctly for the time and service provided.
Why is it so important to document patient consent for every single virtual visit? Documenting consent is a fundamental requirement for both compliance and reimbursement. It serves as proof that the patient agreed to receive care through a virtual format. Payers can deny a claim if consent isn’t clearly noted in the patient’s record for that specific visit. Think of it as a prerequisite; without it, you can’t bill for the service.
The rules for telehealth billing seem to change constantly. How can my practice keep up? Staying on top of evolving telehealth policies is a significant challenge, as rules can vary by payer and change frequently. This is precisely why many practices choose to work with a dedicated billing partner. Having a team of experts manage your revenue cycle ensures someone is always monitoring these updates, so your claims remain accurate and compliant without you having to become a coding policy expert yourself.
Key Takeaways
- Categorize and document each virtual visit accurately: To get paid correctly, you must distinguish between different telehealth services like video calls, audio-only visits, and e-visits, and always document patient consent in their record.
- Apply the correct codes and modifiers to every claim: Match the specific CPT code, Place of Service code (like 02 or 10), and modifier (such as 95 for video or 93 for audio-only) to the service you provided to prevent claim denials.
- Verify telehealth coverage with each payer beforehand: Insurance policies for virtual care are not all the same, so confirm that the provider and service are covered under the patient’s plan before the appointment to secure reimbursement.
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