Information last updated March 17, 2025
Many patients have used telehealth for medical care during the COVID-19 pandemic and continue to seek this option. These resources will help refine and improve virtual care delivery and provide practical implementation tips. For additional coding and billing support, please visit ACP’s Coding for Clinicians modules.
Following the PHE, the Federal government and Congress took steps to extend pandemic-era telehealth flexibilities. Some of the flexibilities were made permanent while others are temporary. Several temporary telehealth flexibles are set to expire September 30, 2025, without Congressional action.
E/M and Other Medicare-Allowed Services
This is a list of eligible CPT/HCPCS codes.
- Use modifier -95 to claim line-item services provided via telehealth.
- Use POS code 10 for telehealth services provided in the patient's home - Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health-related services through telecommunication technology.
- Use POS 02 for telehealth services provided other than in patient's home - Patient is not located in their home when receiving health services or health related services through telecommunication technology.
- Modifier -95 should not be used with virtual check-ins (98016) or digital evaluations (99421-99423). It is for use with all other telehealth codes that use synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system.
- -GQ: Clinicians participating in the federal telehealth demonstration programs in Alaska or Hawaii must submit the appropriate CPT or HCPCS code for the professional service along with the modifier GQ, “via asynchronous telecommunications system.”
- -G0: Use of telehealth for purposes of diagnosing, evaluating, or treating stroke.
- -GT: Medicare stopped using modifier -GT in 2017 when the place of service code 02 (telehealth) was introduced. However, private payers may still be using the modifier -GT.
Virtual Check-In
New in CY 2025: CPT code 98016 will replace HCPCS code G2012 for brief virtual check-ins
Rules:
- Established patients only
- Must be a physician or other qualified health care professional who can report E/M services.
- If an E/M service is provided within the defined time frames, then the virtual check-in is bundled into that E/M service. It would be considered pre- or post-visit time of the associated E/M service and thus not separately billable.
- Should be initiated by the patient since a copay is required. Verbal consent to bill and documentation is required.
Codes:
- No modifier needed as these are technology-based codes.
Code |
Description |
G2010 |
Remote evaluation of recorded video and/or images submitted by an established patient (e.g. store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment. |
98016 |
Brief communication technology-based service, (eg, virtual check-in) by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion. |
Online Digital Evaluation and Management (E/M)
Telehealth-specific codes for the following use cases:
- Can be done synchronously and asynchronously and audio/video phones can be used.
- The patient can initiate a virtual check-in; the practice can inform the patient about their options. If the patient calls back within 7 days, the time from the virtual check-in can be added to the digital E/M code and only the digital E/M code is billed
- If the patient initiates a call to the physician’s office, this would qualify for the remote check-in code (98016); the time for the remote (virtual) check-in can be counted toward 99421-3 only if and when the patient calls back, so it is important to document the time. (See CPT book for details on when the 7 days begins, how to count time, which “qualified non-physician health professionals” it applies to, and other documentation requirements.)
Rules:
- Must be patient initiated.
- Cost sharing applies.
- Use only once per 7-day period. If the patient presents a new, unrelated problem during the 7-day period of an online digital E/M service, the time is added to the cumulative service time for those 7 days.
- Clinical staff time is not calculated as part of cumulative time.
- Service time must be more than 5 minutes.
- Do not count time otherwise reported with other services.
- Do not report on a day when the physician or other qualified health care professional reports other E/M services.
- Do not report when billing remote monitoring, CCM, TCM, care plan oversight, and codes for supervision of patient in home, domiciliary or rest home, etc. for the same communication[s]).
- Do not report for home and outpatient INR monitoring when reporting 93792, 93793.
- No modifier needed as these are technology based codes.
Code | Description |
99421 | Patient-initiated digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes |
99422 | ….11-20 minutes |
99423 | ….21 or more minutes |
Private Payer and State Policies
States vary widely regarding licensure and private payer and Medicaid policies for telehealth.
- The Center for Connected Health Policy (CCHP) is an excellent resource for keeping up with state regulations. CCHP tracks Private Payer Requirements and Telehealth Policies by State. Its information covers Medicaid clarification, waivers, telehealth guidance, prescription and consent waivers, private payer requirements, and cross-state licensing.
- The American Telemedicine Association (ATA) tracks state activity on telehealth including state legislation.
- CMS maintains various resources on State Medicaid Telehealth Coverage, Private Insurance Coverage for Telehealth, and licensure.