COVID-19: Key Take-aways from CMS Guidance for Coding of Telehealth Services

by Gail I. Smith, MA, RHIA, CCS-P

A Medicare Telemedicine Health Care Provider Fact Sheet was released by CMS on March 17, 2020. Link:

CMS is expanding telemedicine benefits with a 1135 waiver that will pay for office, hospital and other visits furnished via telehealth starting with March 6, 2020 and lasting for the duration of the COVID-19 emergency. Medicare beneficiaries will be able to receive services including evaluation and management (E&M), mental health counseling and preventive health screenings. CMS identifies three main types of virtual services and provides billing guidance and specific codes to report services. Included in the Fact Sheet are Key Takeaways and the following table that summarizes the program.

Type of Service What is the Service? HCPCS/CPT Code Patient Relationship with Provider
Medicare Telehealth Visits A visit with the provider that uses telecommunication systems between a provider and a patient Common telehealth services include:

  • 99201-99215 (Office or other outpatient visits)
  • G0425-G0427 (Telehealth consultations, emergency department or initial inpatient)
  • G0406-G0408 (Follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or SNFs

For a complete list:

For new* or established patients
*To the extent that 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency
Virtual Check-in A brief (5-10 minutes) check-in with your practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed. A remote evaluation of recorded video and/or images submitted by an established patient.
  • HCPCS code G2012 (Brief communication technology-based service (virtual check-in code)
  • HCPCS code G2010 (Remote evaluation of recorded video and/or images submitted by an established patient, including interpretation and 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)
For established patients
E-Visits A communication between a patient and their provider through an online patient portal.
  • 99421-99423 E/M section for Online Digital Evaluation and Management Services
  • G2061-G2063 Time-based HCPCS codes for clinicians who may not independently bill for E/M visits (such as physical therapist)
For established patients


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About the Author

Gail Smith, MA, RHIA, CCS-P
Gail I. Smith, President of Gail I. Smith Consulting, is a health care consultant with over 30 years experience in the field of coding, education and health information management (HIM). Gail focuses on ICD-10-CM/PCS education with developing online courses, presenting workshops, and performing documentation reviews. She has authored several coding books for CPT and ICD-10-CM and is an AHIMA approved ICD-10-CM/PCS trainer and Academy faculty member.

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