- Admission and Discharge Services
- Advanced Care Planning
- Behavioral/Mental Health Services
- Chronic Care Management
- Complex and Chronic Care - HCPCS Code G2211
- Consultations
- Critical Care Services
- Documentation
- Emergency Department
- Examination
- Fee-For-Time Compensation Arrangements
- General E/M Information
- Global Period Services
- History
- IPPE and AWV Services
- Medical Decision Making
- New vs. Established Patients
- Nonphysician Practitioner Services
- Observation Services
- Preoperative Clearance
- Prolonged Services
- Provider Specialty
- Scribes
- Separately Identifiable Service
- Skilled Nursing Facility Services
- Smoking Cessation
- Split/Shared and Incident To Services
- Teaching Environment E/M Services
- Telehealth Services
- Time-Based Services
- Transitional Care Management
- Urgent Care
Telehealth Services
- Please explain Medicare’s definition of a telehealth service.
Answer: Medicare defines a telehealth service as a service provided by a Medicare-enrolled practitioner from an approved distant site for a beneficiary who is located at an approved originating site via two-way audio/visual communication technology.
- Please explain the rules for providers who may perform telehealth services for a patient located in a state in which the provider is not licensed.
Answer: CMS does not dictate the guidelines for this scenario, they are decided by each state individually. When considering cross-state telehealth services, providers are advised to review information at Telehealth.HHS.gov:licensing across state lines and pursue further confirmation from individual state licensing boards.
- Please explain appropriate billing for telehealth services when the provider is located at a hospital site and the patient is at home.
Answer: Modifier 95 should be added to all outpatient telehealth services by both physicians and therapists, when the physician or therapist (PT/OT/SLP) is in the hospital and the patient is at home (POS 10).
- Please define payment rates for outpatient telehealth services.
Answer: Telehealth services performed for a patient who is located at a facility-based site (POS 02) will be paid at the facility rate. Telehealth services performed for a patient who is located at a home/residential site (POS 10) will be paid at the non-facility PFS rate. The non-facility rate allows higher reimbursement in order to encourage patient access to all approved telehealth services from home, including mental health services.
- Please explain the guidelines for correct Part B telehealth services.
Answer: Providers performing telehealth services are subject to the following rules:- Regardless of the provider’s location in either an office or facility-related site, the POS on the claim is determined by the patient’s location, which is the originating site.
- Box 32 on the Medicare CMS-1500 claim must include the address from which the provider performed the service. For CY 2025, CMS has continued to waive the requirement for the provider to enter their home address in Box 32. CMS will determine future instructions on this for CY 2026.
- Please explain how POS codes for telehealth services.
Answer: The following POS codes apply to telehealth services:
POS 02: applies to telehealth services for a beneficiary who is located in an approved facility-based originating site. These sites are:- The office of a physician or practitioner
- A hospital (inpatient or outpatient)
- A CAH
- A RHC
- An FQHC
- A hospital-based or CAH-based renal dialysis center (including satellites) (effective 1/1/2009)
- A SNF (effective 1/1/2009)
- A CMHC (effective 1/1/2009)
POS 10: applies to telehealth services for a beneficiary whose originating site is at home. In this context, “home” is defined as the beneficiary’s current living environment and may include the beneficiary’s own home, a vacation home, the home of a family member or friend, a temporary shelter or any other living arrangement that is not facility-based. Through 9/30/2025, CMS will permit services for beneficiaries who are at home in all geographic locations. Beyond 9/30/2025, mental and behavioral health services will continue to remain permanently available for beneficiaries at home in any geographic location within the U.S.
- Please define the list of approved telehealth providers.
Answer: The following providers have been included as approved telehealth practitioners:
- Qualified OTs
- Qualified PTs
- Qualified SLPs
- Qualified Audiologists
- Mental Health Counselors
- Marriage and Family Therapists
- Please explain the rule for practice location on telehealth claims by distant site practitioners.
Answer: Through CY 2025, distant site practitioners may continue to use their currently enrolled practice location instead of their home address, for services performed from the provider’s home location.
- Please define the rules for direct supervision for telehealth services.
Answer: Through CY 2025, when supervising diagnostic tests, physicians’ services and some hospital outpatient services, the supervising professional must be immediately available through virtual presence, via two-way, real-time audio/video technology. Physical presence of the supervising professional is not required.
This virtual presence does not need to be for the full performance of the service, but immediate availability must be maintained throughout the service.
- Please explain the rule for audio-only telehealth services.
Answer: Coverage for these services will continue through 3/31/2025. Since CPT codes 99441–99443 are no longer valid codes, providers are advised to bill these services with correlative E/M codes and add modifier 93 to the service, denoting audio-only service performance.
- Please explain frequency limitations for subsequent telehealth service in the inpatient, nursing facility and critical care settings.
Answer: These services are subject to the following frequency parameters:- Previous limitations on subsequent inpatient and nursing facility services have been removed through 12/31/2025.
- The limitation on ESRD-related visits remains in place. Patients must receive a face to face visit at least monthly during the initial three months of home dialysis and at least once every three consecutive months thereafter.
- Please explain guidelines for telehealth services furnished in teaching settings.
Answer: The following guidelines apply in the teaching setting:- Teaching physicians may perform services personally or in coordination with residents.
- Residents may perform the services when the teaching physician is physically present for the key service elements.
- Residents may perform both in person and virtual telehealth services under virtual supervision of a teaching physician via a three-way audio visual connection.
- Please explain the Medicare telehealth originating site facility fee.
Answer: The Medicare telehealth originating site facility fee is payable to the approved originating site at which the patient receiving the telehealth service was located. The service is represented by HCPCS code Q3014. The CY 2025 fee is paid at 80% of the actual charge or $31.01. The beneficiary is responsible for any unmet deductible amount and Medicare coinsurance. Of note: the originating site fee does not apply to telehealth services performed for beneficiaries located at home.
- Please define CMS modifiers that may be appropriate for mental health services provided via telehealth.
Answer: The following modifiers are required for mental health services provided via telehealth technology for patients at home:- Modifier FQ - A telehealth service was furnished using real- time audio-only communication technology
- Modifier FR - A supervising practitioner was present through a real-time two-way, audio/video communication technology
Reviewed 4/1/2025