Telehealth Billing & Coding for Non-video Phone Calls

As CMS continues to update their policies on Telehealth during the COVID-19 pandemic and the Public Health Emergency, we are here to continue to keep you informed on these changes.

QUESTION: What are requirements to use regular office visit codes (i.e new patient codes, 99201-99205, and established patient codes 99212-99215) with Telehealth? Can regular office visit codes be used for just a phone call between the provider and the patient, that does not include video capability?

ANSWER: No. The provider must use telecommunication application, which mandates audio AND visual, under the Waiver 1135. They can use their smart phone or cell phone for the doctor-to-patient phone calls, and most cell phones have a video chat option. (i.e. Facetime, Skype, Google Duo, Facebook Video Chat).

I know this is causing the confusion. Also, some Medicare-aged patients are resisting and/or refusing the video chat option. This means that the visit is now, Telemedicine, not telehealth, and a phone call code 99441-99443 is the only option between your physician and/or QHP. The visit would need to be timed and still include consent, to report a phone call.

In the CMS chart below note the difference between virtual check-in (which specifically states telephone or telecommunications), however, in Medicare Telehealth visits it states telecommunication system (which mandates audio/video both).


QUESTION: When billing office visit codes for Telehealth, and the 2-way interactive video communications has been met and documented, what is the POS (Place of Service)? We were told 02 for Telehealth in March, but that has changed?

ANSWER: Yes, in the 3/31/2020 CMS published update, CMS changed their position on the 02 POS, as that will reduce services to be paid at a facility rate by about 20%. For continuity, the Waiver flexibilities, was updated to instruct providers to use the POS that would have been used had the patient had a face-to-face visit. So if the patient is at home, but the physician is providing a Telehealth visit from his/her office, the POS would be 11 on the office visit code (99201-99215). You also need to include a -95 modifier to identify the service as delivered via Telehealth.

QUESTION: If the patient was seen in the past 7 days in the office or for a telehealth visit, and now calls for a phone only consultation, can we still bill this as a Virtual Check in (G2012) or a phone call (99441-99443, when they have that 7-day global period?

ANSWER: For the Virtual Check-in code G2012, I would say no. That was specifically tied to a “possible E/M” with the patient. So, if the patient was seen 7 days prior for a related condition, it is an extension of that visit. As for the telephonic visits, 99441-99443 and 98966-98968, the CPT descriptor has similar rules regarding these codes, and CMS has not addressed it. In lieu of clear direction, I would follow CPT. Reminder: Phone calls are not Telehealth so do not add the modifier 95

QUESTION: A patient was seen via audio-video telecommunication, and the video portion stopped connection after 5 minutes due to weather and we could not get it back up. We continued with the audio portion of the Telehealth visit. Can we code for an office visit in this case?

ANSWER: Since the main focus of the visit was done without video chat capabilities, as mandated by the  new waiver in Section 1135(b) of the Social Security Act explicitly allowing the HHS Secretary to authorize use of telephones that have audio and video capabilities for the furnishing of Medicare telehealth services during the COVID-19 PHE.

This visit would now revert to a Telephonic visit, again, codes, 99441-99443, and time would need to be documented to enable the provider to choose the correct code. These are time-based codes.


For continued updates on Telehealth, please order our Telehealth Webinar below. This OnDemand Webinar is updated every 48 hours, as CMS and Commercial Insurers add more updates and changes.

How To Register

Please join Terry Fletcher BS, CPC, CCC, CEMC, CCS, CCS-P, CMC, CMSCS, ACS-CA, SCP-CA, QMGC, QMCRC, QMPM for an on-demand webinar on how to implement these changes and more.

You can register for this session by clicking the button below and scrolling to the down to the register section.

Cost: $199.

Register Now

Categories: Webinar

One Comment

  1. Sree Mura Devi Jagannathan says:

    Is there a free CEU links you offer any for CIRCC certified users?

Leave a Reply

Email will remain private. All fields are required. No html tags alowed.