POLICY
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
Asynchronous store-and-forward technologies means the transmission of a patient’s medical information from an originating site to the physician or practitioner at the distant site. The physician or practitioner at the distant site can review the medical case without the patient being present. An asynchronous telecommunications system in single media format does not include telephone calls, images transmitted via facsimile machines and text messages without visualization of the patient (electronic mail). Photographs visualized by a telecommunications system must be specific to the patient’s medical condition and adequate for furnishing or confirming a diagnosis and or treatment plan. Dermatological photographs, for example, a photograph of a skin lesion, may be considered to meet the requirement of a single media format under this provision.
For Federal telemedicine demonstration programs conducted in Alaska or Hawaii only, Medicare payment is permitted for telehealth when asynchronous store and forward technologies, in single or multimedia formats, are used as a substitute for an interactive telecommunications system.
SOURCE: 42 CFR Sec. 410.78 (Accessed Feb. 2023).
In the case of any Federal telemedicine demonstration program conducted in Alaska or Hawaii, the term “telecommunications system” includes store-and-forward technologies that provide for the asynchronous transmission of health care information in single or multimedia formats.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Feb. 2023).
You must use an interactive audio and video telecommunications system that permits real-time communication between you at the distant site, and the beneficiary at the originating site. Transmitting medical information to a physician or practitioner who reviews it later is permitted only in Alaska or Hawaii Federal telemedicine demonstration programs.
If you performed telehealth services “through an asynchronous telecommunications system”, add the telehealth GQ modifier with the professional service CPT or HCPCS code (for example, 99201 GQ). You are certifying the asynchronous medical file was collected and transmitted to you at the distant site from a Federal telemedicine demonstration project conducted in Alaska or Hawaii.
SOURCE: Medicare Learning Network Factsheet. Telehealth Services, p. 4 & 5, June 2021, (Accessed Feb. 2023).
Temporary Policy – Ends Dec. 31, 2024
Practitioner. The term “practitioner” has the meaning given that term in section 1842(b)(18)(C) [42 USCS § 1395u(b)(18)(C)] and, in the case that the emergency period described in section 1135(g)(1)(B) ends before December 31, 2024, for the period beginning on the first day after the end of such emergency period and ending on December 31, 2024, shall include a qualified occupational therapist (as such term is used in section 1861(g) [42 USCS § 1395x(g)]), a qualified physical therapist (as such term is used in section 1861(p) [42 USCS § 1395x(p)]), a qualified speech-language pathologist (as defined in section 1861(ll)(4)(A) [42 USCS § 1395x(ll)(4)(A)), and a qualified audiologist (as defined in section 1861(ll)(4)(B) [42 USCS § 1395x(ll)(4)(B)).
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) as amended by HR 2617 (2022 Session). (Accessed Feb. 2023).
Home Health (HH) Agencies
Starting on or after January 1, 2023, they may voluntarily report the use of telecommunications technology in providing HH services on HH payment claims. CMS will require this information on HH claims starting on July 1, 2023. Home Health Agencies will submit the use of telecommunications technology on the HH claim using the following 3 G-codes:
- G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
- G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
- G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)
SOURCE: Telehealth Home Health Services: G-Codes, MLN Matters MM12805, (Effective Date: Jan. 1, 2023), (Accessed Feb. 2023).
ELIGIBLE SERVICES/SPECIALTIES
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
The term “telehealth service” means professional consultations, office visits, and office psychiatry services (identified as of July 1, 2000, by HCPCS codes 99241–99275, 99201–99215, 90804–90809, and 90862 (and as subsequently modified by the Secretary)), and any additional service specified by the Secretary. The Secretary shall establish a process that provides, on an annual basis, for the addition or deletion of services (and HCPCS codes), as appropriate.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Feb. 2023).
Medicare Part B pays for covered telehealth services included on the telehealth list when furnished by an interactive telecommunications system if certain conditions are met, except that for the duration of the Public Health Emergency as defined in § 400.200 of this chapter, Medicare Part B pays for office and other outpatient visits, professional consultation, psychiatric diagnostic interview examination, individual psychotherapy, pharmacologic management and end stage renal disease related services included in the monthly capitation payment furnished by an interactive telecommunications system if certain conditions are met.
SOURCE: 42 CFR Sec. 410.78 (Accessed Feb. 2023).
Changes to the list of Medicare telehealth services are made through the annual physician fee schedule rulemaking process. During the Public Health Emergency for the COVID-19 pandemic, as defined in § 400.200 of this chapter, we will use a sub-regulatory process to modify the services included on the Medicare telehealth list during the Public Health Emergency taking into consideration infection control, patient safety, and other public health concerns resulting from the emergency. A list of the services covered as telehealth services under this section is available on the CMS website.
SOURCE: 42 CFR Sec. 410.78 (Accessed Feb. 2023).
List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth is available on the CMS website, including temporary codes during the public health emergency. Find the complete List of Telehealth Services by downloading the ZIP and opening the Excel or text files.
SOURCE: Medicare Learning Network Factsheet. Telehealth Services, p. 5, June 2021 & CMS Telehealth List Year 2023. (Accessed Feb. 2023).
The Secretary shall pay to a physician or practitioner located at a distant site that furnishes a telehealth service to an eligible telehealth individual an amount equal to the amount that such physician or practitioner would have been paid under this title had such service been furnished without the use of a telecommunications system.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Feb. 2023).
The physician or practitioner at the distant site must be licensed to furnish the service under State law. The physician or practitioner at the distant site who is licensed under State law to furnish a covered telehealth service may bill, and receive payment for, the service when it is delivered via a telecommunications system.
The practitioner at the distant site is one of the following:
- A physician
- A physician
- A nurse practitioner
- A clinical nurse specialist
- A nurse-midwife
- A clinical psychologist
- A clinical social worker
- A registered dietitian or nutrition professional
- A certified registered nurse anesthetist
SOURCE: 42 CFR Sec. 410.78 & Medicare Learning Network Factsheet. Telehealth Services, p. 4, June 2021 (Accessed Feb. 2023).
Eligible Sites:
- The office of a physician or practitioner.
- A critical access hospital
- A rural health clinic
- A Federally qualified health center
- A hospital
- A hospital-based or critical access hospital- based renal dialysis center (including satellites).
- A skilled nursing facility
- Rural emergency hospital
- A community mental health center
- A renal dialysis facility for purposes of individuals with end-stage renal disease getting home dialysis.
- The home of an individual, but only for purposes of individuals with end-stage renal disease getting home dialysis or telehealth services to treat substance use disorder or individuals with co-occurring mental health disorders, or mental health disorders under certain circumstances.
- Mobile Stroke Unit
- The home of a beneficiary for the purposes of diagnosis, evaluation, and/or treatment of a mental health disorder for services furnished on or after the first day after the end of the PHE as defined in our regulation at § 400.200 except as otherwise provided in this paragraph. Payment will not be made for a telehealth service furnished under this paragraph unless the following conditions are met:
- The physician or practitioner has furnished an item or service in-person, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service;
- The physician or practitioner has furnished an item or service in-person, without the use of telehealth, at least once within 12 months of each subsequent telehealth service described in this paragraph, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens associated with an in-person service outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reason(s) for this decision in the patient’s medical record.
- The requirements of paragraphs (b)(3)(xiv)(A) and (B) may be met by another physician or practitioner of the same specialty and subspecialty in the same group as the physician or practitioner who furnishes the telehealth service, if the physician or practitioner who furnishes the telehealth service described under this paragraph is not available.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m) & Medicare Learning Network Factsheet. Telehealth Services, p. 4 & 5 [some info excluded due to document being out of date] & 42 CFR Sec. 410.78. (Accessed Feb. 2023).
Temporary Policy – Ends Dec. 31, 2024 – Delay of In-Person mental health requirement
In general. Payment may not be made under this paragraph for telehealth services furnished on or after January 1, 2025 (or, if later, the first day after the end of the emergency period described in 1395(g)(1)(B)) by a physician or practitioner to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder unless such physician or practitioner furnishes an item or service in person, without the use of telehealth, for which payment is made under this title (or would have been made under this title if such individual were entitled to, or enrolled for, benefits under this title at the time such item or service is furnished)—
- Within the 6-month period prior to the first time such physician or practitioner furnishes such a telehealth service to the eligible telehealth individual; and
- During subsequent periods in which such physician or practitioner furnishes such telehealth services to the eligible telehealth individual, at such times as the Secretary determines appropriate.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) as amended by HR 2617 (2022 Session). (Accessed Feb. 2023).
Providers qualify as originating sites, regardless of location, if they were participating in a Federal telemedicine demonstration project approved by (or getting funding from) the U.S. Department of Health & Human Services.
SOURCE: Medicare Learning Network Factsheet. Telehealth Services, p. 3, June 2021, (Accessed Feb. 2023).
Communication Technology-Based Services (CTBS)
CMS makes separate payment for remote evaluation of recorded video and/or images submitted by the patient. The code, G2010 describes 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.
HCPCS code G2010 may be billed only for established patients. The follow-up with the patient could take place via phone call, audio/video communication, secure text messaging, email, or patient portal communication.
SOURCE CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Feb. 2023).
Online digital evaluation services (e-visit) are reimbursable for physicians and qualified non-physician health care professionals. These are non-face-to-face codes that describe patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.
SOURCE CY 2020 Final Physician Fee Schedule. CMS, p. 799, (Accessed Feb. 2023).
Interprofessional consultations are reimbursable by CMS as part of their CTBS services (CPT codes include 99451, 99452, 99446, 99447, 99448, and 99449). Cost sharing will apply. These interprofessional services may be billed only by practitioners that can bill Medicare independently for evaluation and management services. Includes telephone and internet assessments.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Feb. 2023).
Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes communication technology-based services (Includes the Brief Communication Technology-Based Service, Remote Evaluation of Pre-Recorded Patient Information) to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.
G0071 should be billed for both services.
SOURCE: Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, & Virtual Communication Services RHCs and FQHCs FAQs, December 2018, (Accessed Feb. 2023).
RHCs and FQHCs are not eligible for reimbursement of interprofessional consultation services, as only practitioners that can bill Medicare independently for evaluation and management services are eligible.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Feb. 2023).
GEOGRAPHIC LIMITS
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
For asynchronous store and forward telecommunications technologies, the only originating sites are Federal telemedicine demonstration programs conducted in Alaska or Hawaii.
SOURCE: 42 CFR Sec. 410.78 (Accessed Feb. 2023).
Temporary Policy – Ends Dec. 31, 2024
Expanding access to telehealth services. In the case that the emergency period described in section 1135(g)(1)(B) ends before December 31, 2024, with respect to telehealth services identified in subparagraph (F)(i) as of the date of the enactment of this clause [enacted March 15, 2022] that are furnished during the period beginning on the first day after the end of such emergency period and ending on December 31, 2024, the term “originating site” means any site in the United States at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system, including the home of an individual.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) as amended by HR 2617 (2022 Session). (Accessed Feb. 2023).
Permanent Policy
The term “originating site” means only those sites described below:
- In an area that is designated as a rural health professional shortage area under section 332(a)(1)(A) of the Public Health Service Act
- In a county that is not included in a Metropolitan Statistical Area; or
- From an entity that participates in a Federal telemedicine demonstration project that has been approved by (or receives funding from) the Secretary of Health and Human Services as of December 31, 2000.
The geographic requirements shall not apply with respect to telehealth services furnished on or after January 1, 2019, for purposes of the home dialysis monthly ESRD-related visit, at a hospital-based or critical access hospital-based renal dialysis center, a renal dialysis facility, or the home.
Additional exceptions exist for treatment of acute stroke and substance use disorder (see below).
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Feb. 2023).
An originating site is the location where a Medicare patient gets physician or practitioner medical services through a telecommunications system. The patient must go to the originating site for the services located in either:
- County outside a Metropolitan Statistical Area (MSA)
- Rural Health Professional Shortage Area (HPSA) in a rural census tract
The Health Resources and Services Administration (HRSA) decides HPSAs and the Census Bureau decides MSAs. Find potential Medicare telehealth originating site payment eligibility at HRSA’s Medicare Telehealth Payment Eligibility Analyzer.
SOURCE: Medicare Learning Network Factsheet. Telehealth Services, p. 3, June 2021, (Accessed Feb. 2023).
Substance Use Disorder
The geographic requirements shall not apply with respect to telehealth services furnished on or after July 1, 2019, to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder, as determined by the Secretary, or, on or after the first day after the end of the emergency period described in section 1135(g)(1)(B), subject to subparagraph (B), to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder, as determined by the Secretary at any originating site except a renal dialysis facility.
Requirements for mental health services furnished through telehealth
Payment may not be made under this paragraph for telehealth services furnished by a physician or practitioner to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder unless such physician or practitioner furnishes an item or service in person, without the use of telehealth, for which payment is made under this title:
- within the 6-month period prior to the first time such physician or practitioner furnishes such a telehealth service to the eligible telehealth individual; and
- during subsequent periods in which such physician or practitioner furnishes such telehealth services to the eligible telehealth individual, at such times as the Secretary determines appropriate.
These requirements do not apply to services:
- Under this paragraph (with respect to telehealth services furnished to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder); or
- Under this subsection without application of this paragraph.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Feb. 2023).
Originating sites must be:
- Located in a health professional shortage area (as defined under section 332(a)(1)(A) of the Public Health Service Act that is either outside of a Metropolitan Statistical Area (MSA) as of December 31st of the preceding calendar year or within a rural census tract of an MSA as determined by the Office of Rural Health Policy of the Health Resources and Services Administration as of December 31st of the preceding calendar year, or
- Located in a county that is not included in a Metropolitan Statistical Area as defined in section 1886(d)(2)(D) of the Act as of December 31st of the preceding year, or
- An entity participating in a Federal telemedicine demonstration project that has been approved by, or receive funding from, the Secretary as of December 31, 2000, regardless of its geographic location.
The geographic requirements specified above do not apply to the following telehealth services:
- Home dialysis monthly ESRD-related clinical assessment services furnished on or after January 1, 2019, at a hospital-based or critical access hospital-based renal dialysis center, a renal dialysis facility, or the home; and
- Services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke.
- Services furnished on or after July 1, 2019 to an individual with a substance use disorder diagnosis, for purposes of treatment of a substance use disorder or a co-occurring mental health disorder.
- Services furnished on or after the first day after the end of the PHE as defined in our regulation at § 400.200 for the purposes of diagnosis, evaluation, and/or treatment of a mental health disorder. Payment will not be made for a telehealth service furnished under this paragraph unless the physician or practitioner has furnished an item or service in person, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service and within 6 months of any subsequent telehealth service.
SOURCE: 42 CFR Sec. 410.78 (Accessed Feb. 2023).
The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act removed originating site geographic conditions and added an individual’s home as a permissible originating telehealth services substance use disorder or co-occurring mental health treatment site.
SOURCE: Medicare Learning Network Factsheet. Telehealth Services, p. 3, June 2021, (Accessed Feb. 2023).
Requirements for mental health services furnished through telehealth
Payment may not be made under this paragraph for telehealth services furnished on or after the day that is the 152nd day after the end of the emergency period described in section 1320b–5(g)(1)(B) of this title) by a physician or practitioner to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder unless such physician or practitioner furnishes an item or service in person, without the use of telehealth, for which payment is made under this subchapter (or would have been made under this subchapter if such individual were entitled to, or enrolled for, benefits under this subchapter at the time such item or service is furnished)—
- within the 6-month period prior to the first time such physician or practitioner furnishes such a telehealth service to the eligible telehealth individual; and
- during subsequent periods in which such physician or practitioner furnishes such telehealth services to the eligible telehealth individual, at such times as the Secretary determines appropriate.
These requirements do not apply to services:
- Under this paragraph (with respect to telehealth services furnished to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder); or
- under this subsection without application of this paragraph.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Feb. 2023).
Communication Technology-Based Services (CTBS)
Geographic limits do not apply to Communication Technology-Based Services.
TRANSMISSION FEE
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
Eligible originating sites are eligible for a facility fee equal to:
- for the period beginning on October 1, 2001, and ending on December 31, 2001, and for 2002, $20; and
- for a subsequent year, the facility fee specified in subclause (I) or this subclause for the preceding year increased by the percentage increase in the MEI (as defined in section 1842(i)(3)) for such subsequent year.
No facility fee shall be paid under this subparagraph to an originating site that is the home.
Treatment of Acute Stroke: No facility fee shall be paid to an originating site with respect to a telehealth service if the originating site does not otherwise meet the requirements for an originating site, including geographic requirements.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Feb. 2023).
HCPCS Code Q3014 describes the Medicare telehealth originating sites facility fee. Bill your MAC for the separately billable Part B originating site facility fee. The originating site facility fee does not count toward the number of services used to determine payment for partial hospitalization services when a CMHC serves as an originating site.
SOURCE: Medicare Learning Network Factsheet. Telehealth Services, p. 5, June 2021, (Accessed Feb. 2023).
No facility fee for new sites. In the case that the emergency period described in section 1135(g)(1)(b) ends before December 31, 2024, with respect to telehealth services identified in paragraph (4)(F)(i) as of the date of the enactment of this clause [enacted March 15, 2022] that are furnished during the period beginning on the first day after the end of the emergency period and ending December 31, 2024 described in section 1135(g)(1)(B) [42 USCS § 1320b-5(g)(1)(B)], a facility fee shall only be paid under this subparagraph to an originating site that is described in paragraph (4)(C)(ii) (other than subclause (X) of such paragraph).
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) as amended by HR 2617 (2022 Session). (Accessed Feb. 2023).
Communication Technology-Based Services (CTBS)
No originating site or transmission fee for Communication Technology-Based Services.
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