Telehealth Services

January 16th, 2021

Audio-only Visits
In 2020, CMS finalized policies to cover audio-only E/M services on an interim basis. Audio-only E/M services (CPT codes 99441-43) are currently reimbursed at a rate comparable to levels 2 to 4 office/outpatient E/M visits throughout the duration of the COVID-19 public health emergency (PHE).

In its 2021 final rule, CMS stated that at the end of the PHE, there will no longer be separate payment for audio-only E/M visit codes. Instead, it is creating a new code on an interim basis. G2252 is a virtual check-in, involving 11-20 minutes of medical discussion to determine the necessity of an in-person visit, that will be available through 2021. Payment for G2252 is equivalent to payment for CPT code 99442 (wRVU of .50). CMS considers this code to be a communication technology-based service and states that it will be subject to the same billing requirements as G2012.

Additions to the Telehealth Service List
CMS added nine services to the Medicare telehealth list on a permanent basis (Category 1 basis). CMS also finalized a third temporary category for adding services to the Medicare telehealth list. This category, known as Category 3, describes services added to the list during the COVID-19 PHE that will remain on the list through the end of the calendar year in which the PHE ends.

Summary of CY 2021 Services Added to the Medicare Telehealth Services List

Type of Service

Specific Services and CPT Codes

Services finalized for permanent addition as Medicare Telehealth Services

  • Group Psychotherapy (CPT 90853)
  • Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT 99334-99335)
  • Home Visits, Established Patient (CPT 99347-99348)
  • Cognitive Assessment and Care Planning Services (CPT 99483)
  • Visit Complexity Inherent to Certain Office/Outpatient E/Ms (HCPCS G2211)
  • Prolonged Services (HCPCS G2212)
  • Psychological and Neuropsychological Testing (CPT 96121)

Services finalized to remain temporarily on the Medicare telehealth list through the end of the year in which the PHE for COVID-19 ends (Category 3 services), to allow for continued development of evidence to demonstrate clinical benefit and facilitate post-PHE care transitions.

  • Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT 99336-99337)
  • Home Visits, Established Patient (CPT 99349-99350)
  • Emergency Department Visits, Levels 1-5 (CPT 99281-99285)
  • Nursing facilities discharge day management (CPT 99315-99316)
  • Psychological and Neuropsychological Testing ( CPT 96130-96133; CPT 96136-96139)
  • Therapy Services, Physical and Occupational Therapy, All levels (CPT 97161-97168; CPT 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507) and Hospital discharge day management (CPT 99238-99239)
  • Inpatient Neonatal and Pediatric Critical Care, Subsequent (CPT 99469, 99472, 99476)
  • Continuing Neonatal Intensive Care Services (CPT 99478-99480)
  • Critical Care Services (CPT 99291-99292)
  • End-Stage Renal Disease Monthly Capitation Payment codes (CPT 90952, 90953, 90956, 90959, and 90962)
  • Subsequent Observation and Observation Discharge Day Management (CPT 99217; CPT 99224-99226)


Frequency Limitations in Nursing Facility Settings

CMS finalized a policy to allow subsequent nursing visits to be furnished via Medicare telehealth once every 14 days in the nursing facility setting. CMS is not finalizing any revisions to the frequency limitations on inpatient visits or critical care consultations provided as telehealth services.

Direct Supervision by Interactive Telecommunication Technology

CMS finalized its proposal to allow direct supervision to be provided using real-time, interactive audio and video technology through the later of the end of the calendar year in which the COVID-19 PHE ends or Dec. 31, 2021.

Communication Technology-Based Services (CTBS)

CMS finalized its proposal to allow non-physician practitioners (NPPs), such as licensed clinical social workers (LCSWs), clinical psychologists, physical therapists (PTs), occupational therapists (OTs), and speech language pathologists (SLPs) to bill G2061 through G2063 (otherwise known as eVisits), consistent with the scope of these practitioners’ benefit categories.

The eVisit G codes will now be replaced with CPT codes 98970-98972. CMS also finalized its proposal to allow billing of G2250 (Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward) and G2251 (virtual checkin) by certain NPPs, consistent with the scope of these practitioners’ benefit categories.

CMS will identically value G2250 and G2251 to G2010 and G2012, respectively. Finally, CMS finalized its proposal to designate G2250, G2251, G2061, G2062, and G2063 as “sometimes therapy” services to facilitate billing of these codes by therapists.