Evaluation and Management FAQs

Telehealth Services

Note: View National Government Services' Place of Service Codes for CY 2024 Updates

  1. 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.
     
  2. Please explain appropriate use for modifier 95 in CY 2024.

    Answer:
    For CY 2024, 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.
     
  3. Please define payment rates for outpatient telehealth services in CY 2024.

    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.
     
  4. 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.
    • The provider must be enrolled in the MAC for the location from which he/she performs the service.
    • The provider must be licensed in the state in which the patient is located, whether this is a POS 02 (facility-based site) or POS 10 (patient’ home). For example:
      • A NY provider who is rendering a telehealth service to a patient who is located at an originating site (either POS 02 or POS 10) in NJ must be licensed in both NY and NJ.
      • A NY provider who renders care to a NJ patient in his/her NY office must be licensed in NY but is not required to be licensed in NJ.
    • Box 32 on the Medicare CMS-1500 claim must include the address from which the provider performed the service. For CY 2024, CMS has waived the requirement for the provider to enter their home address in Box 32. CMS will determine future instructions on this for CY 2025.
       
  5. Please explain how POS codes for telehealth services will change in 2024.

    Answer: As of 1/1/2024, the following POS codes will 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.
     
  6. Please explain the status of approved telehealth services for 2024.

    Answer:
    CMS has defined two categories for telehealth services: Permanent and Provisional. Services currently on the Telehealth List as Category 1 or Category 2 are now considered permanent. Services added on a “temporary” Category 2 or Category 3 basis are now considered provisional. This means they are billable and payable now and will be evaluated for permanent status. The full list of services is available at: 2024 List of Telehealth Services
     
  7. Please define CY 2024 additions to telehealth services.

    Answer:
    In CY 2024 CMS has designated a permanent category to HCPCS G0136, representing Social Determinants of Health Risk Assessments and a provisional category to Health and Well-being coaching services. The coaching services have been temporarily added to the Medicare Telehealth Services List:
    • CPT code 0591T: Health and well-being coaching face-to-face; individual, initial assessment;
    • CPT code 0592T: Health and well-being coaching face-to-face; individual, follow-up session, at least 30 minutes; and
    • CPT code 0593T: Health and well-being coaching face-to-face; group (2 or more individuals), at least 30 minutes.
       
  8. Has the list of approved telehealth practitioners been expanded for 2024?

    Answer: For services included on the Medicare Telehealth Services list as of 3/15/2020 and 12/31/2024, 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
       
  9. Please explain the rule for practice location on telehealth claims by distant site practitioners in CY 2024.

    Answer:
    Through CY 2024, 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.
     
  10. Please define the CY 2024 rules for direct supervision for telehealth services.

    Answer: 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.
     
  11. Please explain the rule for audio-only telehealth services in CY 2024.

    Answer: Coverage for these services will continue through CY 2024, and services payable via this technology are included on the Medicare List of Telehealth Services.
     
  12. 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.
    • 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.
       
  13. Please explain guidelines for telehealth services furnished in teaching settings in CY 2024.

    Answer: The following guidelines apply in the teaching setting:
    • Teaching physicians may perform services personally.
    • Residents may perform the services when the teaching physician is physically present for the key service elements.
    • In all geographic locations, residents may perform virtual telehealth services under virtual supervision of a teaching physician.
    • In all areas outside of a Metropolitan Statistical Areas (MSA), residents may perform both in person and virtual telehealth services under virtual supervision of a teaching physician.
       
  14. Please explain the status of telephone evaluation and management Services for CY 2024.

    Answer: CPT codes 99441-99443 and 98966-98968, representing audio-only visits will remain on the telehealth list through CY 2024.
     
  15. 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 2024 fee is paid at 80% of the actual charge or $29.96. 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.
     
  16. Please define CMS modifiers that may be appropriate for mental health services provided via telehealth.

    Please note: These modifiers may be used in 2024, but will not be required until CY 2025, depending on CMS guidelines expected in the CMS Final Rule for 2025.

    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

Revised 2/27/2024