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NGS Telehealth Billing FAQs for COVID-19


  1. What has changed in Medicare coverage for telehealth services?

    Answer: There are 85 new codes added to the list of services that can be delivered via telehealth.
        • List of Telehealth Services
        • Geographic restrictions temporarily waived
        • Home added as an originating site
        • Frequency limitations for hospital and SNF visits waived


  1. What services are available to allow patient care and communication during the current health crisis?

    Answer: Communication options include
      • Defined telehealth services (see List of Telehealth Services) which require audio and visual communication (Note: of all codes listed here, only codes on this list should be billed with modifier 95)
      • Audio-only telephone communication (99441‒99443) by physicians, osteopaths, optometry and NPPs
      • Audio-only telephone communication (98966‒98968) by physical therapy, occupational therapy, optometry, LCSW and clinical psychologist
      • Virtual check-in G2012 for virtual communication performed by physicians, osteopaths, optometry and NPPs
      • G2010 for remote review of video or images performed by physicians, osteopaths, optometry and NPPs
      • Physician/NPP e-visit via patient portal (99421‒99423)
      • Nonphysician e-visits via patient portal (G2061‒G2063) (e.g., physical and occupational therapy) clinical psychologists, NPPs, LCSW


  1. Some E/M services require performance of 3/3 elements (history, examination and MDM). May these services be performed via telehealth?

    Answer: Yes, these services may be performed via telehealth.

    As per CMS-1744-IFC, E/M level selection may be based on MDM or time (for office/outpatient services), and the requirement for documentation of a history and/or examination has been temporarily waived.

    Examination via telehealth is limited, but it is permissible for a provider to document pertinent observations such as skin color, skin lesions/rashes, quality of respiration and evidence of wheezing or dyspnea, vital signs as reported by the patient. When this is done, these factors may also contribute to the level of coding.

  2. Can time-based E/M services be performed via telehealth?

    Answer: Yes, a time-based E/M service, during which > 50% of time is spent in counseling/ coordination of care, may be performed via telehealth. Counseling/coordination of care time will not come into play if you choose to follow the 2021 E/M guidelines for office and other outpatient services that the AMA has posted. (Updated 5/19/2020)

  3. Can initial hospital services (99221‒99223) be performed via telehealth?

    Answer: Yes, both initial (99221‒992230) and subsequent (99231‒99233) hospital services can be performed via telehealth.

  4. Can consultation services be performed without F2F patient contact?

    Answer: G0425‒G0427 represent initial inpatient or emergency room consultation via telehealth. G0406‒G0408 represent f/u inpatient consultation services via telehealth.

    Note: When a consultant’s opinion is required without F2F contact, the service may be represented by the inter-professional consultation codes CPT codes 99451, 99452, 99446, 99447, 99448 and 99449 which do not require any F2F contact by the consulting physician. See Final Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2019.

    Note: E/M services performed for a hospitalized patient by a provider within the same hospital are not telehealth services and should be billed as usual, without the modifier 95.

  5. Can critical care be performed via telehealth?

    Answer: Critical care telehealth consultation:
        • G0508 (initial 60 minutes of communication)
        • G0509 (subsequent 50 minutes of communication)

          Direct critical care by the attending provider:
        • 99291 (initial 74 minutes of critical care)
        • 99292 (each additional 30 minutes of critical care)

          Bill these services with the place of service from which the provider performs the service and use modifier 95 when performed via telehealth from an off-site location. Modifier 95 does not apply when the provider and the patient are located in the same hospital setting. (Updated 4/29/2020)
  1. During the COVID-19 PHE, resident is on-site, sees inpatient by telephone in order to reduce exposure risk. Resident then speaks to teaching physician about the patient. Can the teaching physician bill the service using normal E/M codes?

    Yes, this would be acceptable during the PHE. CMS has indicated that the supervision requirement is met during this time if the physician is available and discusses the patient care with the resident. They do not have to provide direct, over the shoulder supervision. (Added 4/29/2020)

  2. We collect the specimen via a swab for a COVID-19 lab test. What code do we bill for this collection?

    Answer: G2023 has been implemented for clinical labs to bill when they obtain the specimen. If you are not a clinical lab then nasal swabs are included in the appropriate code for any E/M service that is provided that day. However, the Interim Final Rule issued April 30 by CMS clarified that if the visit was just for specimen collection, such as a drive through clinic, providers may bill 99211 for that collection, even if the physician does not see the patient. (Added 5/21/2020)


  1. May all Medicare-enrolled providers bill for telehealth services?

    Answer: Please refer to the MLN® Booklet: Telehealth Services.

    These providers may perform approved telehealth services that are within their approved scope of practice and within CMS coverage guidelines.

    Medicare-enrolled providers who may bill telehealth services are:

        • Physicians
        • NPs
        • PAs
        • Nurse-midwives
        • CNSs
        • Certified registered nurse anesthetists
        • CPs and CSWs
          • Note: CPs and CSWs cannot bill Medicare for psychiatric diagnostic interview examinations with medical services or medical evaluation and management services. They cannot bill or get paid for CPT codes 90792, 90833, 90836 and 90838
        • Registered dietitians or nutrition professional
  1. Can PT/OT/SLP providers perform and bill services via telehealth?

    Answer: Yes, CMS has added PT/OT/SLP providers to the list of provider types who may perform services via telehealth. In addition to the CMS-defined PT services, these providers may perform and bill Communications Technology-Based-Services. These include telephone communication services represented by CPTs 98966-98969 and e-visits via patient portals represented by CPTs G2061-G2063. Two things of note

    1. The CTBS services are not telehealth services and do not require Modifier 95.
    2. When provided by therapists in private practice or therapists in institutional providers of therapy services, the CTBS codes are always provided under a physical therapy, occupational therapy, or speech-language pathology plan of care and must be reported with the associated GP, GO, or GN therapy modifier. Please refer to MLN Matters®: MM11791 Revised: Therapy Codes Update for additional details. (Updated 6/4/2020)

  2. What provider types can bill for telephone communication (audio only) codes 98966-98968?

    Answer: NPPs, CNS, PAs, CNMs, CPs, SLPs, PTs, OTs, CSWs, registered dietitians or nutrition professionals and optometrists. (Added 4/30/2020)
  1. What provider types can bill for telephone communication (audio only) codes 99441‒99443?

Answer: Physicians, osteopaths, podiatrists, optometrists, dentists, NPs, CNSs, PAs, CNMs and maxillofacial surgeons. (Added 4/28/2020)

Sites and Place of Service

  1. What are the approved distant sites from which a provider may perform a telehealth service?

    Answer: Approved providers may perform telehealth services from any location at which the provider is able to establish an audio/visual communication with a patient and all other standard criteria are met.
  2. Is there a specific place of service for a telehealth service claim?


    Preferred Billing: For all telehealth services, provider should bill the site of service from which it is performed (e.g., office POS 11, hospital POS 21) and add a modifier 95 to the service.

    Permissible Billing: Telehealth claims submitted with POS 02 will continue to process but also require modifier 95.

  3. When a telehealth service is performed for a patient who is at home, how is the originating site fee billed?

    When the originating site is the patient’s home, no claim is filed for an originating site fee.

  4. If a provider performs a telehealth service from his/her home, what is the place of service and correct address on the claim?

    Answer: If a provider is performing the service from home due to COVID-19 personal restriction(s) or at the provider’s convenience after usual office hours, the address on the claim should be that from which the provider customarily bills services to Medicare. If a provider is performing the service from a home-based office at which he/she is enrolled with Medicare, then the home-based office address is used on the claim.

  5. Do telehealth services provided by a provider-based clinic or hospital qualify for both a facility fee and a professional claim?

    Answer: Under these circumstances, only the distant site professional fee is billable. No facility fee applies when a telehealth service is performed from these sites. Note: When a patient is in a hospital room and the provider is not in the room but is on the hospital campus, using audio/visual technology, this is not a telehealth service. This should be billed as though performed F2F and the medical record should describe the actual non F2F circumstance.

    : In both of these instances, a provider can use NGSConnex to correct their claim. If you are not an NGSConnex user, you can contact our Telephone Reopening Unit.
  6. Should on-site visits conducted via video or through a window in the clinic suite be reported as telehealth services?

    No, services should only be reported as telehealth services when the individual physician or professional providing the telehealth service is not at the same location as the beneficiary. However, such services may be reportable as a regular visit. (Added 4/29/2020)

  7. How do I correct a claim if place of service 02 was billed instead of place of service 11? What if I forgot to add the modifier 95?

    In both of these instances, a provider can use NGSConnex to correct their claim. If you are not an NGSConnex user, you can contact our Telephone Reopening Unit. (Added 4/29/2020)  


  1. What modifiers are needed for telehealth claims?

    Answer: Services provided via telehealth require a modifier 95. Telehealth claims submitted by CAHs still require modifier GT. Rules for other previously used modifiers remain the same (e.g., modifier 25) and these may be used as applicable.

  2. When is Modifier CS used on a claim for a telehealth service?

    Answer: Physician and practitioner services that lead to either an order for OR administration of a COVID-19 lab test, are not subject to copay or deductible charges. Modifier CS is added to the physician/practitioner service to define this circumstance and allow the claim to process without co-pay or deductible application. During either a telehealth or F2F service, the provider may order a COVID-19 test or perform a COVID-19 test. Modifier CS is added to the claim for either of these visits. This applies to all pertinent claims with date of service 3/18/2020 and thereafter.

  3. When performing a telephone service only, do we append the 95 modifier? And, what place of service do we use?

    Answer: Bill the place of service code where the provider would have performed the service if it had been performed F2F (usually the provider’s office, POS 11). Since telephone services have been added to the list of approved CMS telehealth services, a Modifier 95 is now required on these claims. (Updated 5/22/2020)

Other Topics

  1. Are prolonged non F2F codes allowed for phone calls (99441‒99443, 98966‒98968) and telehealth visits?

    Answer: Non F2F prolonged service codes, 99358‒99359 can be billed with telephone services (99443 and 98968 would be reported for the first 30 minutes). 99358‒99359 are also allowed for telehealth visits. Please remember that CPT Code 99358 is for the first hour of non-face-to-face services and may be billed before or after direct patient care. CPT 99359 is an add-on code, only billable in conjunction with 99358. So in the case of these codes, a provider must spend 31 minutes or more before billing code 99358 and 76 minutes or more before adding code 99359. (Added 4/29/2020)
Revised 6/4/2020
Revised 6/2/2020
Revised 5/22/2020
Revised 5/21/2020
Posted 4/14/2020
Last Modified: 6/4/20
NGS Telehealth Billing FAQs for COVID-19
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