CMS telehealth billing 3-17-20

As we look more into the news from CMS today, we will share here, as well as via our webpage at
Here are two important components for telehealth billing as of today’s announcement:
  • The following codes (as well as many more) are allowed for telehealth visits
    • 99201 Office/outpatient visit new
      99202 Office/outpatient visit new
      99203 Office/outpatient visit new
      99204 Office/outpatient visit new
      99205 Office/outpatient visit new
      99211 Office/outpatient visit est
      99212 Office/outpatient visit est
      99213 Office/outpatient visit est
      99214 Office/outpatient visit est
      99215 Office/outpatient visit est
  • I don’t know yet whether the pre-2018 practice of using a GT or GQ modifier will be appropriate, or if indicating a Place of Service of 02 will be a better option. There is a very good document from the American Academy of Pediatrics that indicates when modifier or POS is most appropriate, which by applying todays exemptions seems to make things a little easier to understand.
  • Zoom video conferencing has a free platform for 1:1 visits, however for larger scale team use we would suggest one of the paid versions.

CMS Telehealth updates 3-17-20

CMS has just announced the lifting of some key restrictions on telehealth, including the ability for patients and providers to use “telephones that have audio and video capabilities”.  This means that in addition to quality video software like Zoom, regular old iPhone Facebook video calls qualify for telehealth use!

We are currently helping many of our clients get setup with remote work tools, and will add telehealth tools to the list of solutions we can help implement.
Please call us at 916-538-4588 or email if you would like to look at solutions!
Ben Hardt
Owner, Vandelay Industries
From MGMA earlier today:


March 17, 2020

COVID-19 regulatory alert: Medicare telehealth restrictions lifted

Today, the Centers for Medicare & Medicaid Services (CMS) issued guidance on Secretary Azar’s waiver authority that broadens access to Medicare telehealth services. Effective March 6, 2020 and for the duration of the COVID-19 Public Health Emergency, CMS will:

  • Waive geographic restrictions, meaning patients can receive telehealth services in non-rural areas;
  • Waive originating site restrictions, meaning patients can receive telehealth services in their home;
  • Allow use of telephones that have audio and video capabilities; 
  • Allow reimbursement for any telehealth covered code, even if unrelated to COVID-19 diagnosis, screening, or treatment; and
  • Not enforce the established relationship requirement that a patient see a provider within the last three years.

The Medicare telemedicine healthcare provider fact sheet can be found here. The Medicare FAQ on these telehealth waivers can be found here. The Enforcement Discretion for telehealth remote communications during the COVID-19 notice can be found here.

This announcement follows MGMA efforts to encourage CMS to expeditiously expand telehealth coverage in response to the public health emergency. 

Visit the MGMA COVID-19 Action Center for the latest developments impacting medical practices.


Contact MGMA Government Affairs by emailing or calling 202.293.3450, 877.275.6462 toll-free