Telehealth Coverage Policies during COVID-19 Pandemic

Updated on April 6, 2020, as things rapidly develop regarding what we know about COVID-19, telehealth coverage policies have also been developing alongside it. Below is a summary of what is covered by various public and private payers with the information that has been released.

Medicare Fee for Service Telehealth Coverage

SUBJECT AREA	CURRENT POLICY UNDER COVID-19
Location of the Patient	Rural and site limitations are removed. Telehealth services can now be provided regardless of where the enrollee is located geographically and type of site, which allows the home to be an eligible originating site. Existing policies on facility fee prior to COVID-19 changes apply
Eligible Services	Medicare expanded the list of eligible services provided via telehealth.
Eligible Providers	Physicians Nurse practitioners Physician assistants Nurse-midwives Clinical nurse specialists Certified registered nurse anesthetists Clinical psychologists (CP) Clinical social workers (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 Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and 90838). Registered dietitians or nutrition professional FQHCs/RHCs (during the emergency period only)
Modality	CMS clarified in their Final Interim Rule that for telehealth services a “telecommunications system” would mean “multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.”
Out-of-pocket costs/co-pays	Still applies, but the OIG is providing health care providers flexibility to reduce or waive fees.
Prior existing relationship to provide care via telehealth	Services via telehealth and remote patient monitoring and virtual check-in can be provided to new and established patients.
End Stage Renal Disease & Home Dialysis Patients	CMS exercising enforcement discretion on requirement that home dialysis patients receiving services via telehealth must have a monthly face-to-face, non-telehealth encounter in the first initial three months of home dialysis and after the first initial three months, at least once every three consecutive months. ESRD clinicians no longer must have one “hands on” visit/month for current required examination of vascular access site. Clinicians will not have to meet the National Coverage Determination or Local Coverage Determination of face-to-face visit for evaluations and assessments during this public health emergency.
Nursing Homes	CMS waiving requirement that physicians and non-physician practitioners perform in-person visit for nursing home residents and if appropriate, allow them to be done via telehealth.
Hospice	During an emergency period, the Secretary may allow telehealth to meet the requirement that a hospice physician or nurse practitioner must conduct a face-to-face encounter to determine continued eligibility for hospice care.
Frequency Limitations	The pre-COVID-19 frequency limitations on subsequent in-patient visit (once every three days), subsequent SNF visit (once every 30 days), and critical care consult (once a day) were removed.
Stark Laws	CMS allowing certain waivers: hospitals and other health care providers can pay above or below fair market value to rent equipment or receive services from physicians; health care providers can support each other financially to ensure continuity of health care operations; and others
Modifiers	Per the final interim rule, providers are allowed to report POS code that would have been reported had the service been furnished in person so that providers can receive the appropriate facility or non-facility rate and use the modifier “95” to indicate the service took place through telehealth. If providers wish to continue to use POS code 02, they may and it pays the facility rate.

Other Medicare & Medicaid Policies

Temporarily waive Medicare and Medicaid requirements to be licensed in the patient state if they are enrolled in Medicare, have valid license in the state which relates to Medicare enrollment, in furnishing services in the state where there emergency is occurring, and not excluded from practicing in that state or any other state that is part of the emergency. State requirements will still apply.

EXISTING TELEHEALTH POLICY PRE-COVID-19	POLICY CHANGE IN RESPONSE TO COVID-19	WHAT CAN BE COVERED
Medicare Advantage
Medicare Advantage (MA) plans have the flexibility to have more expansive telehealth policies related to types of services covered, where those services can take place (no geographic or site limitations), modality used. Still limits the types of providers reimbursed.	Medicare Advantage Organizations were informed by CMS that if they wish to expand coverage of telehealth services beyond what has already been approved by CMS, they will exercise its enforcement discretion until it is determined that it is no longer necessary in conjunction with the COVID-19 outbreak.	MA plans have some flexibility to expand their coverage of telehealth beyond what they currently do. What is covered will depend on what each plan decides to do. NOTE: MA plans do NOT have to provide these more expansive telehealth services. They are only required to provide what is covered by Fee-for-Service.
Other Technology-Enabled Services
Virtual Check-In Codes G2010, G2012* Can be done synchronously and asynchronously and telephone can be used	Other providers such as PTs, OTs and speech language pathologists may bill these codes as well as G2061-G2063.	Virtual check-in codes do not have geographic or site restrictions attached so they can be used to engage with patients, but the reimbursement amount for these codes is low and are only meant to act as quick check-ins with patients that do not last more than a few minutes.
Inter-professional Telephone/Internet/EHR Consultations (eConsult) * 99446, 99447, 99448, 99449, 99451, 99452	No Change Made	eConsult allows a provider-to provider consultation. Pays both providers, but check definition for the time needed for each code.
Remote monitoring services: * Chronic Care Management Complex Chronic Care Management Transitional Care Management Remote Physiologic Monitoring Principle Care Management	No Change Made	These services are not considered “telehealth” services and were never subject to telehealth limitations. They do have other factors that limit how they can be used so make sure you check the definition for the codes.
Online Digital Evaluation (E- *Visit) – G2061-2063 Online medical Evaluations – 99421-99423	No Changes Made	These services are not considered “telehealth” services and were never subject to telehealth limitations.
Telephone E/M Services	Added by Interim Final Rule	98966-98968; 99441-99443
Medicaid
EXISTING TELEHEALTH POLICY PRE-COVID-19	POLICY CHANGE IN RESPONSE TO COVID-19	WHAT WILL BE COVERED AT THIS TIME
Telehealth reimbursement policies vary from state to state. If the State Medicaid program has managed care, telehealth reimbursement can vary from plan-to-plan.	A Medicaid FAQ was issued stating that state Medicaid programs have broad authority to utilize telehealth within their Medicaid programs including using telehealth or telephonic consultations in place of typical face-to-face requirements when certain conditions are met. States would have to use the Appendix K process for this. As noted above, licensure requirements were waived for Medicaid, though state requirements would still apply	Still developing. Some states have encouraged providers and health plans to utilize telehealth more broadly to provide services but for many states the policies continue to be developing as they navigate this situation.
Private Insurers
EXISTING TELEHEALTH POLICY PRE-COVID-19	POLICY CHANGE IN RESPONSE TO COVID-19	WHAT WILL BE COVERED AT THIS TIME
Coverage varied from payer-to payer, depending on the plan.	Several health plans have announced that they will make telehealth more widely available or offering telehealth services for free for a certain period of time. Some of the announcements have come from Aetna, Cigna and BlueShield BlueCross. Additionally, Vice President Pence had announced that he had secured a commitment from the health plans to cover telehealth services, but no details or which plans had agreed were given.	Still developing. Few details have been given and would require individuals to inquire with their insurer what is exactly covered. Montana health plans recently agreed to cover telehealth delivered services.