Last updated 04/02/2025
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Interactive telecommunications system may also include two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system as defined as multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication, but the patient is not capable of, or does not consent to, the use of video technology.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
CY 2024 Physician Fee Schedule notes that section 4113 of Division FF, Title IV, Subtitle A of the Consolidated Appropriations Act, 2023 (CAA, 2023) (Pub. L. 117-328, December 29, 2022) extends the telehealth policies enacted in the Consolidated Appropriations Act, 2022 (CAA, 2022) (Pub. L. 117-103, March 15, 2022) through December 31, 2024, if the PHE ends prior to that date, as discussed in section II.D.c. of this final rule. These provisions included:
- Temporarily removing the geographic and site requirements for the patient location at the time the telehealth interaction takes place
- Temporarily allowing a more expansive list of eligible providers in Medicare to provide services via telehealth such as physical and occupational therapists and federally qualified health centers (FQHCs) and rural health clinics (RHCs)
- Temporarily allowing some services to continue to be provided via audio-only
- Temporarily suspending the in-person service requirement prior to the delivery of mental and behavioral services via telehealth or audio-only in cases where the geographic requirement does not apply, the service takes place in the home and the patient was not being treated for a substance use disorder
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
Also see Table 11 for list of eligible codes (including those eligible for audio-only) in CY 2024 Physician Fee Schedule.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
For most non-behavioral or mental telehealth, you must use 2-way, interactive, audio-video technology. Section 4113 of the Consolidated Appropriations Act, 2023 allows you to use audio-only telehealth for some non-behavioral or mental telehealth through December 31, 2024.
Starting January 1, 2025, you may use 2-way, interactive, audio-only technology if the distant site provider is technically capable of using an audio-video telehealth system and the patient is in their home but isn’t capable of, or doesn’t consent to, using video technology.
For behavioral or mental telehealth, you may use 2-way, interactive, audio-only technology. The patient must be in their home.
As of July 1, 2023, you must report the use of telehealth technology in providing HH services on HH payment claims. See MLN Matters Article MM12805 for more information.
You must submit the use of telecommunications technology on the HH claims using the following 3 HCPCS codes:
- G0320: Home health services you furnish using synchronous telehealth you render via real-time audio video telehealth
- G0321: Home health services you furnish using synchronous telehealth you render via telephone or another real-time, interactive, audio-only telehealth
- G0322: The collection of physiologic data the patient digitally stores or transmits to the HH agency
See fact sheet for additional details.
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Temporary Policy – Ends Dec. 31, 2024
In the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, the Secretary shall continue to provide coverage and payment under this part for telehealth services identified in paragraph (4)(F)(i) as of March 15, 2022, that are furnished via an audio-only communications system during the period beginning on the first day after the end of such emergency period and ending on September 30, 2025. For purposes of the previous sentence, the term “telehealth service” means a telehealth service identified as of March 15, 2022, by a HCPCS code (and any succeeding codes) for which the Secretary has not applied the requirements of paragraph (1) and the first sentence of section 410.78(a)(3) of title 42, Code of Federal Regulations, during such emergency period.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) (Accessed Mar. 2025).
Q6: Can beneficiaries continue to receive audio-only telehealth services? Are audio-only telehealth services permitted in all originating sites?
A6: Pursuant to the American Relief Act, 2025, physicians and practitioners may continue to use two-way, real-time audio-only communication technology for Medicare telehealth services furnished through March 31, 2025.
After March 31, 2025, physicians and practitioners may continue to use two-way, real-time audio-only communication technology to furnish Medicare telehealth services in accordance with the revised definition of “interactive telecommunications system”. In the CY 2025 PFS final rule, CMS permanently changed the definition of “interactive telecommunications system” to include two-way, real-time audio-only communication technology for any telehealth service furnished to a patient in their home, provided that the furnishing physician or practitioner is technically capable of using audio-video communication technology and that the beneficiary is not capable of or does not consent to using audio-video communication technology. Audio-only can be used for both new and established patients. Beneficiaries who are receiving remote mental health services, as defined in the CY 2023 and 2024 OPPS Final Rules, furnished by hospital-employed staff in their homes may permanently receive these via audio-only communication technology.
Pursuant to the American Relief Act, 2025, audio-only telehealth services are permitted in all originating sites through March 31, 2025. However, in general, audio-only telehealth services are only permitted if the beneficiary is in their home. All other originating sites are medical facilities that generally have the infrastructure and broadband capacity to support two-way, audio/video communication technology. Additionally, patients would not have the same heightened expectation of privacy when video is used for a Medicare telehealth service in a medical facility as they would in their home.
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
Periodic Assessments for Opioid Use Disorder (OUD) by Opioid Treatment Provider (OTP) – CMS will extend periodic assessments by OTPs to the end of 2024. The audio-only option will only be available if video is not and to the extent audio-only is permitted by SAMHSA and Drug Enforcement Administration (DEA) and all other relevant requirements.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
Interactive telecommunications system means, except as otherwise provided in this paragraph (a)(3), 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. Interactive telecommunications system may also include two-way, real-time audio-only communication technology for any telehealth service furnished to a patient in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system as defined in the previous sentence, but the patient is not capable of, or does not consent to, the use of video technology. The following modifiers must be appended to a claim for telehealth services furnished using two-way, real-time audio-only communication technology to verify that the conditions set forth in the prior sentence have been met:
- Current Procedural Terminology (CPT) modifier “93”; and
- For rural health clinics (RHCs) and federally qualified health centers (FQHCs), Medicare modifier “FQ”.
SOURCE: 42 CFR Sec. 410.78 (Accessed Dec. 2024).
Mental Health Services
CMS revised definition of ‘interactive telecommunications system’ above to include audio-only communication technology. They will create a service-level modifier for use to identify mental health telehealth services furnished to a beneficiary in their home using audio-only communications technology.
SOURCE: CY 2022 Physician Fee Schedule, CMS, p. 214-215, (Accessed Mar. 2025).
The 2 additional modifiers for CY 2022 relate to telehealth mental health services. The modifiers are:
- FQ – A telehealth service was furnished using real-time audio-only communication technology
- FR – A supervising practitioner was present through a real-time two-way, audio/video communication technology
SOURCE: CY2022 Telehealth Update Medicare Physician Fee Schedule, MLN Matters 12549, (Jan. 1, 2022), (Accessed Mar. 2025).
FQHCs & RHCs Mental Health Services
Mental health visit includes audio-only interaction in cases where beneficiaries are not capable of, or do not consent to, the use of devices that permit a two-way, audio/video interaction for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
RHCs and FQHCs can report and be paid for furnishing those visits in the same way they currently do when these services are furnished in-person. RHCs and FQHCs will be paid for mental health visits furnished via telecommunications technology at the same rate they are paid for in-person mental health visits (that is, the AIR or FQHC PPS).
There must be an in-person mental health service furnished within 6 months prior to the furnishing of the telecommunications service and that in general, there must be an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders. This applies only to patients receiving services at home. If the patient and practitioner consider the risks and burdens of an in-person service and agree that, on balance, these outweigh the benefits, and the practitioner documents the basis for that decision in the patient’s medical record, then the in-person visit requirement is not applicable for that 12-month period.
In person requirement delayed under Medicare until on or after January 1, 2025.
SOURCE: CY 2022 Physician Fee Schedule, CMS, p. 214-215 & delay in implementation in HR 2617 (2022 Session). (Accessed Mar. 2025).
RHCs and FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. You may use audio-only technology in situations when your patient can’t access or doesn’t consent to use audio-video technology. You can report and get paid in the same way as in-person visits.
- Audio-video visits: Use modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System).
- Audio-only visits: Use new service-level modifier FQ or 93.
These in-person visit requirements apply only to a patient getting mental health visits via telecommunications at home:
- There must be an in-person mental health visit 6 months before the telecommunications visit
- In general, there must be an in-person mental health visit at least every 12 months while the patient is getting services from you via telecommunications to diagnose, evaluate, or treat mental health disorders
NOTE: Section 4113 of the Consolidated Appropriations Act (CAA), 2023, delayed the in-person visit requirements under Medicare for mental health visits that RHCs and FQHCs provide via telecommunications technology. For RHCs and FQHCs, we won’t require in-person visits until January 1, 2025.
SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Mar. 2025).
We may cover these behavioral health and wellness services:
- Interactive telecommunications, including 2-way, interactive audio-only technology to diagnose, evaluate, or treat certain mental health or SUDs using telehealth services if the patient is in their home
- Hospital clinical staff must have the capability to provide 2-way, interactive, audio-video technology services but may use audio-only technology given an individual patient’s technological limitations, abilities, or preferences
- You can provide telehealth using 2-way, interactive, audio-only technology through December 31, 2024
- Telehealth services provided to people in their homes will be paid at the non-facility PFS rate through December 31, 2024
- Marriage and family therapist (MFT) services (also available through telehealth)
- Mental health counselor (MHC) services (also available through an acceptable telehealth mental health disorder service site)
- Addiction counselors or alcohol and drug counselors who meet the applicable MHC requirements can enroll in Medicare as MHCs
- SUD treatment in a patient’s home (an acceptable telehealth substance use treatment or a co-occurring mental health disorder service site)
Beginning in 2025, in-person visit requirements will apply for mental health services provided by telehealth.
This includes a required in-person visit within the 6 months before the initial telehealth treatment as well as the required subsequent in-person visits at least every 12 months.
We’ll continue to define direct supervision to permit the immediate availability of the supervising practitioner through real-time audio and visual interactive telecommunications through December 31, 2024.
The regulations at 42 CFR 410.78(b)(3)(xiv) describe 2 exceptions to the in-person requirements that take effect on January 1, 2025:
- Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate
- Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability
The telehealth policies described above also apply to Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
Beginning January 1, 2024, MHCs and MFTs can provide and bill Medicare telehealth services.
Exceptions to the in-person visit requirement require a clear justification documented in the patient’s medical record. Hospitals must also document that patients have a regular source of general medical care and can get any needed point-of-care testing, including vital sign monitoring and lab studies.
We created 3 Outpatient Prospective Payment System (OPPS)-specific HCPCS codes to describe that the patient must be in their home and that no associated professional service is billed under the PFS. Hospital staff must be licensed to provide these services consistent with all applicable state scope of practice laws. We exempt these services from having staff physically located in the hospital or outpatient department when providing services remotely using communication technology. See booklet for list of codes.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Learning Network Booklet 1986542, Medicare & Mental Health Coverage, July 2024, (Accessed Mar. 2025).
A mental health visit is a medically-necessary face-to-face encounter between an RHC or FQHC patient and an RHC or FQHC practitioner during which time one or more RHC or FQHC mental health services are rendered. Effective January 1, 2022, a mental health visit is a face-to-face encounter or an encounter furnished using interactive, real-time, audio and video telecommunications technology or audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
Beginning January 1, 2025, there must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.
RHCs and FQHCs are instructed to append modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) in instances where the mental health visit was furnished using audio-video communication technology and to append modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) in cases where the service was furnished using audio-only communication.
Mental health services that qualify as stand-alone billable visits in an FQHC are listed on the FQHC center website, http://www.cms.gov/Center/Provider-Type/FederallyQualified-Health-Centers-FQHC- Center.html. Services furnished must be within the practitioner’s state scope of practice.
Medicare-covered mental health services furnished incident to an RHC or FQHC visit are included in the payment for a medically necessary mental health visit when an RHC or FQHC practitioner furnishes a mental health visit. Group mental health services do not meet the criteria for a one-one-one, face-to-face encounter in an FQHC or RHC.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 9/12/24, pg. 43 (Accessed Mar. 2025).
Communication Technology-Based Services (CTBS)
‘Brief communication technology-based service, e.g. virtual check-in’ allows for real-time audio-only telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Mar. 2025).
Interprofessional consultations are reimbursable by CMS as part of their CTBS services (CPT codes include 99451, 99452, 99446, 99447, 99448, and 99449). Cost sharing will apply. These interprofessional services may be billed only by practitioners that can bill Medicare independently for evaluation and management services. Includes telephone and internet assessments.
SOURCE CY 2019 Final Physician Fee Schedule. CMS, p. 31-40 (Accessed Mar. 2025).
Online digital evaluation services (e-visit) are reimbursable for physicians and qualified non-physician health care professionals. These are non-face-to-face codes that describe patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.
SOURCE: CY 2020 Final Physician Fee Schedule. CMS, p. 799 (Accessed Mar. 2025).
Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes these services to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.
RHCs and FQHCs may only bill for these services when the medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and does not lead to an RHC or FQHC service within the next 24 hours or at the soonest available appointment, since in those situations, Medicare already pays for the services as part of the RHC or FQHC per-visit payment.
RHCs and FQHCs can bill G0511, G0512, and G0071 alone or with other payable services on an RHC or FQHC claim.
SOURCE: Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, (Accessed Mar. 2025).
RHCs and FQHCs are not eligible for reimbursement of interprofessional consultation services, as only practitioners that can bill Medicare independently for evaluation and management services are eligible.
SOURCE CY 2019 Final Physician Fee Schedule. CMS, p. 31-40 (Accessed Mar. 2025).
New codes created that allow clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors to bill for interprofessional consultations with other practitioners whose practice is similarly limited, as well as with physicians and practitioners who can bill Medicare for E/M services and would use the current CPT codes to bill for interpersonal consultations. These new G codes for behavioral health services were finalized: G0546-G0551. Patient consent must be obtained in advance of the services.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
Home Health Agencies
An individualized plan of care must be established and periodically reviewed by the certifying physician or allowed practitioner. The plan of care must include all of the following: … Any provision of remote patient monitoring or other services furnished via telecommunications technology (as defined in § 409.46(e)) or audio-only technology. Such services must be tied to the patient-specific needs as identified in the comprehensive assessment, cannot substitute for a home visit ordered as part of the plan of care, and cannot be considered a home visit for the purposes of patient eligibility or payment.
Telecommunications technology, as indicated on the plan of care, can include: remote patient monitoring, defined as the collection of physiologic data (for example, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient or caregiver or both to the home health agency; teletypewriter (TTY); and 2-way audio-video telecommunications technology that allows for real-time interaction between the patient and clinician. The costs of any equipment, set-up, and service related to the technology are allowable only as administrative costs. Visits to a beneficiary’s home for the sole purpose of supplying, connecting, or training the patient on the technology, without the provision of a skilled service, are not separately billable.
SOURCE: 42 CFR Sec. 409.43 & 409.46, (Accessed Mar. 2025).
Starting on or after January 1, 2023, they may voluntarily report the use of telecommunications technology in providing HH services on HH payment claims. CMS will require this information on HH claims starting on July 1, 2023. Home Health Agencies will submit the use of telecommunications technology on the HH claim using the following 3 G-codes:
- G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
- G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
- G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)
SOURCE: Telehealth Home Health Services: G-Codes, MLN Matters MM12805, (Effective Date: Jan. 1, 2023), (Accessed Mar. 2025).
Teleradiology
Interpretation Provided Telephonically by Wireless Remote: Teleradiology services (radiology services that do not require a face-to-face encounter with the patient furnished through the use of a telecommunications system) are discussed in Pub. 100-02, Medicare Benefit Policy Manual, chapter 15, section 30. The interpretation of an x-ray, electrocardiogram, electroencephalogram and tissue samples are listed as examples of these services.
In cases where the face-to-face requirement is obviated such as those when a physician/practitioner provides the PC/interpretation of a diagnostic test, from a distant site, the POS code assigned by the physician /practitioner shall be the setting in which the beneficiary received the TC service. The POS code for a teleradiology interpretation is generally the place where the beneficiary received the TC, or face-to-face encounter. The POS code representing the setting where the beneficiary received the TC is entered in the ASC X12 837 professional claim format or in item 24B on the paper claim Form CMS 1500. In cases where it is unclear which POS code applies, the Medicare contractor can provide guidance.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 13: Radiology Services and Other Diagnostic Procedures, 11/16/23, pg. 62, (Accessed Mar. 2025).
Opioid Treatment Programs
During the Public Health Emergency (PHE) for the COVID-19 pandemic, as well as after the conclusion of the PHE, therapy and counseling may be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology if two-way audio/video communications technology is not available to the beneficiary, provided all other applicable requirements are met, including circumstances in which the beneficiary is not capable of or does not consent to the use of devices that permit a two-way audio/video interaction
OTPs are allowed to furnish the substance use counseling, individual therapy, and group therapy included in the bundle via two-way interactive audio-video communication technology, as clinically appropriate, in order to increase access to care for beneficiaries. In addition, initiation of treatment with buprenorphine (but not methadone) via the OTP intake add-on code may be furnished via two-way audio-video communications technology to the extent that the use of audio-video telecommunications technology to initiate treatment with buprenorphine is authorized by DEA and SAMHSA at the time the service is furnished. For additional information please refer to Section 20 – Definitions relating to OTPs, C. Opioid use disorder treatment service. During the Public Health Emergency (PHE) for the COVID-19 pandemic, as well as after the conclusion of the PHE, therapy and counseling may be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology if two-way audio/video communications technology is not available to the beneficiary, provided all other applicable requirements are met, including circumstances in which the beneficiary is not capable of or does not consent to the use of devices that permit a two-way audio/video interaction.
Beginning January 1, 2021, OTPs are allowed to use two-way interactive audio-video communication technology, as clinically appropriate, to furnish the periodic assessment add-on code. Additionally, during the PHE which expired on May 11, 2023, in cases where a beneficiary did not have access to two-way audio-video communications technology, periodic assessments could be furnished using audio-only telephone calls if all other applicable requirements were met. Through the end of CY 2024, in cases where a beneficiary does not have access to two-way audio-video communications technology, periodic assessments can be furnished using audio-only telephone calls if all other applicable requirements are met.
Beginning January 1, 2023, OTPs are allowed to furnish the OTP intake add-on code via two-way audio- video communication technology when billed for the initiation of treatment with buprenorphine, to the extent that the use of audio-video telecommunications technology to initiate treatment with buprenorphine is authorized by DEA and SAMHSA at the time the service is furnished. OTPs are also allowed to use audio- only communication technology to initiate treatment with buprenorphine in cases where audio-video technology is not available to the beneficiary, including circumstances in which the beneficiary is not capable of or has not consented to the use of devices that permit a two-way, audio/video interaction.
OTPs providing intensive outpatient services to Medicare beneficiaries with an OUD shall not receive payment under Medicare part B if the intensive outpatient services are furnished via audio-video or audio-only communications technology.
Telemedicine services should not, under any circumstances, expand the scope of practice of a healthcare professional or permit practice in a jurisdiction (the location of the patient) where the provider is not licensed.
Counseling or therapy furnished via communication technology as part of OUD treatment services furnished by an OTP must not be separately billed by the practitioner furnishing the counseling or therapy because these services would already be paid through the bundled payment made to the OTP.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 17: Opioid Treatment Programs (OTPs), 12/21/23, (Accessed Mar. 2025).
Aligning with recent regulations previously adopted by the Substance Abuse and Mental Health Services Administration (SAMHSA), CMS finalized the following: …
- Allow opioid treatment programs (OTPs) to furnish periodic assessments via audio-only on a permanent basis if live video is not available, if certain requirements are met and if they are permitted under applicable SAMHSA and DEA requirements
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
No reference found for email and fax.
* The US Health and Human Services Administration maintains a website that summarizes Medicare policies that includes audio-only allowances.
Last updated 03/31/2025
Live Video
POLICY
The Secretary shall pay for telehealth services that are furnished via a telecommunications system by a physician (as defined in section 1861(r)) or a practitioner (described in section 1842(b)(18)(C)) to an eligible telehealth individual enrolled under this part notwithstanding that the individual physician or practitioner providing the telehealth service is not at the same location as the beneficiary.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
We pay for specific Medicare Part B services that a physician or practitioner provides via 2-way, interactive technology (or telehealth). Telehealth substitutes for an in-person visit, and generally involves 2-way, interactive technology that permits communication between the practitioner and patient.
During the COVID-19 public health emergency (PHE), we used emergency waiver and other regulatory authorities so you could provide more services to your patients via telehealth. Section 4113 of the Consolidated Appropriations Act, 2023 extended many of these flexibilities through December 31, 2024, and made some of them permanent. Section 3207 of the American Relief Act, 2025 extended many of these flexibilities through March 31, 2025.
Starting April 1, 2025, the statutory limitations that were in place for Medicare telehealth services before the COVID-19 PHE will retake effect for most telehealth services. These include:
- Geographic restrictions
- Location restrictions on where you can provide services
- Limitations on the scope of practitioners who can provide telehealth services
Billing and Payment
- Bill covered telehealth to your Medicare Administrative Contractor (MAC). They pay you the appropriate telehealth amount under the Physician Fee Schedule (PFS).
- Submit professional telehealth claims using the appropriate CPT or HCPCS code.
- If you performed telehealth through asynchronous telehealth, add the telehealth GQ modifier with the professional service CPT or HCPCS code. You’re certifying you collected and sent the asynchronous medical file at the distant site from a federal telemedicine demonstration conducted in Alaska or Hawaii.
- Distant site practitioners billing telehealth under the CAH Optional Payment Method II must submit institutional claims using the GT modifier.
- If you’re located in, and you reassigned your billing rights to, a CAH and elected the outpatient Optional Payment Method II, the CAH bills the MAC for telehealth. The payment is 80% of the PFS distant site facility amount for the distant site service.
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Requirements for mental health services furnished through telehealth (Delay of In-Person mental health requirement)
Payment may not be made under this paragraph for telehealth services furnished on or after October 1, 2025, by a physician or practitioner to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder unless such physician or practitioner furnishes an item or service in person, without the use of telehealth, for which payment is made under this subchapter (or would have been made under this subchapter if such individual were entitled to, or enrolled for, benefits under this subchapter at the time such item or service is furnished)—
- within the 6-month period prior to the first time such physician or practitioner furnishes such a telehealth service to the eligible telehealth individual; and
- during subsequent periods in which such physician or practitioner furnishes such telehealth services to the eligible telehealth individual, at such times as the Secretary determines appropriate.
This subparagraph shall not apply if payment would otherwise be allowed—
- under this paragraph (with respect to telehealth services furnished to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder); or
- under this subsection without application of this paragraph.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
In addition to the requirement for the in-person visit mentioned above in statute, CMS will also require there to be an in-person, non-telehealth service within 12 months of each mental health telehealth service. However, if the patient and practitioner agree that the benefits of an in-person, non-telehealth service within 12 months of the mental health telehealth service are outweighed by risks and burdens associated with an in-person service, and the basis for that decision is documented in the patient’s medical record, the in-person visit requirement will not apply for that particular 12-month period. CMS will allow a clinician’s colleague in the same subspecialty in the same group to furnish the in-person, non-telehealth service to the beneficiary if the original practitioner is unavailable. [Implementation delayed until January 1, 2025.]
See eligible providers section for additional information for federally qualified health centers (FQHCs) and rural health clinics (RHCs).
SOURCE: CY 2022 Physician Fee Schedule, CMS, p. 63, (Accessed Mar. 2025).
Background
Section 223 of the Medicare, Medicaid and SCHIP Benefits Improvement and Protection Act of 2000 (BIPA) – Revision of Medicare Reimbursement for Telehealth Services amended §1834 of the Act to provide for an expansion of Medicare payment for telehealth services.
Effective October 1, 2001, coverage and payment for Medicare telehealth includes consultation, office visits, individual psychotherapy, and pharmacologic management delivered via a telecommunications system. Eligible geographic areas include rural health professional shortage areas (HPSA) and counties not classified as a metropolitan statistical area (MSA). Additionally, Federal telemedicine demonstration projects as of December 31, 2000, may serve as the originating site regardless of geographic location.
An interactive telecommunications system is required as a condition of payment; however, BIPA does allow the use of asynchronous “store and forward” technology in
delivering these services when the originating site is a Federal telemedicine demonstration program in Alaska or Hawaii. BIPA does not require that a practitioner present the patient for interactive telehealth services.
With regard to payment amount, BIPA specified that payment for the professional service performed by the distant site practitioner (i.e., where the expert physician or practitioner is physically located at time of telemedicine encounter) is equal to what would have been paid without the use of telemedicine. Distant site practitioners include only a physician as described in §1861(r) (go to the link and select the applicable title) of the Act and a medical practitioner as described in §1842(b)(18)(C) (go to the link and select the applicable title) of the Act. BIPA also expanded payment under Medicare to include a $20 originating site facility fee (location of beneficiary).
Previously, the Balanced Budget Act of 1997 (BBA) limited the scope of Medicare telehealth coverage to consultation services and the implementing regulation prohibited the use of an asynchronous, ‘store and forward’ telecommunications system. BBA 1997 also required the professional fee to be shared between the referring and consulting practitioners, and prohibited Medicare payment for facility fees and line charges associated with the telemedicine encounter.
BIPA required that Medicare Part B (Supplementary Medical Insurance) pay for this expansion of telehealth services beginning with services furnished on October 1, 2001.
Section 149 of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) amended §1834 of the Act to add certain entities as originating sites for payment of telehealth services. Effective for services furnished on or after January 1, 2009, eligible originating sites include a hospital-based or critical access hospital-based renal dialysis center (including satellites); a skilled nursing facility (as defined in §1819(a) of the Act); and a community mental health center (as defined in §1861(ff)(3)(B) of the Act). MIPPA also amended§1888(e)(2)(A)(ii) of the Act to exclude telehealth services furnished under §1834(m)(4)(C)(ii)(VII) from the consolidated billing provisions of the skilled nursing facility prospective payment system (SNF PPS).
NOTE: MIPPA did not add independent renal dialysis facilities as originating sites for payment of telehealth services.
The telehealth provisions authorized by §1834(m) of the Act are implemented in 42 CFR 410.78 and 414.65.
Conditions of Payment
For Medicare payment to occur, interactive audio and video telecommunications must be used, permitting real-time communication between the distant site physician or practitioner and the Medicare beneficiary. As a condition of payment, the patient must be present and participating in the telehealth visit.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 165-166, 174, (Accessed Mar. 2025).
* The US Health and Human Services Administration maintains a website that summarizes Medicare policies.
ELIGIBLE SERVICES/SPECIALTIES
Frequency limitations for inpatient visits, nursing facilities and critical care consults were among the COVID-19 waivers that were extended to the end of 2024. CMS will continue to suspend the frequency limitations through 2025 for the following services:
- Subsequent Inpatient Visits – 99231-99233
- Subsequent Nursing Facility Visits – 99307-99310
- Critical Care Consultations – G0508-G0509
CMS states that they will continue to evaluate patient safety and look to minimizing disruption of services as much as possible.
CMS will continue to allow use of video to meet direct supervision requirements in specific cases:
- Through December 31, 2025, continue to allow live video to be used by the supervising practitioner to meet “immediate availability” definition.
- Allow live video (audio-only would be excluded) to be used to meet the requirement of the presence of the physician/practitioner for direct supervision in certain incident-to services provided by auxiliary personnel employed by the physician and working under their direct supervision.
- Through December 31, 2025, continue to allow teaching physicians to have a virtual presence for billing purposes when services are furnished by residents in any residency training location but only when the service is furnished via telehealth.
- Continue to allow the current flexibility for federally qualified health centers (FQHCs) and Rural Health Clinics (RHCs) to use live video to meet the “immediately available” requirement for direct supervision to December 31, 2025.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
Hospitals
After consideration of the public comments we received, we are finalizing, without modification, our proposal to revise §§ 410.27(a)(1)(iv)(B)(1) and 410.28(e)(2)(iii) to allow for the direct supervision of CR, ICR, PR services and diagnostic services via audio-video real-time communications technology (excluding audio-only) through December 31, 2025.
SOURCE: Center for Medicare and Medicaid Services, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems CY 2025 Rule, CMS-1809-FC, 11/27/24, (Accessed Mar. 2025).
We’ll temporarily suspend telehealth frequency limitations on subsequent inpatient (CPT codes 99231, 99232, 99233, 99307, 99308, 99309, and 99310) and nursing facility visits and on critical care consultations (HCPCS codes G0508 and G0509) through CY 2025.
SOURCE: CMS Medicare Learning Network (MLN) Telehealth Services, MLN 901705 (Jan. 2025). (Accessed Mar. 2025).
Permanent Policy
Subject to paragraph (8), the term “telehealth service” means professional consultations, office visits, and office psychiatry services (identified as of July 1, 2000, by HCPCS codes 99241–99275, 99201–99215, 90804–90809, and 90862 (and as subsequently modified by the Secretary)), and any additional service specified by the Secretary.
The Secretary shall establish a process that provides, on an annual basis, for the addition or deletion of services (and HCPCS codes), as appropriate, to those specified in clause (i) for authorized payment under paragraph (1).
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
The use of a telecommunications system may substitute for an in-person encounter for professional consultations, office visits, office psychiatry services, and a limited number of other physician fee schedule (PFS) services. The various services and corresponding current procedure terminology (CPT) or Healthcare Common Procedure Coding System (HCPCS) codes are listed on the CMS website at www.cms.gov/Medicare/MedicareGeneral-Information/Telehealth/
NOTE: Beginning January 1, 2010, CMS eliminated the use of all consultation codes, except for inpatient telehealth consultation G-codes. CMS no longer recognizes office/outpatient or inpatient consultation CPT codes for payment of office/outpatient or inpatient visits. Instead, physicians and practitioners are instructed to bill a new or established patient office/outpatient visit CPT code or appropriate hospital or nursing facility care code, as appropriate to the particular patient, for all office/outpatient or inpatient visits.
Telehealth Consultation Services, Emergency Department or Initial Inpatient versus Inpatient Evaluation and Management (E/M) Visits
A consultation service is an evaluation and management (E/M) service furnished to evaluate and possibly treat a patient’s problem(s). It can involve an opinion, advice, recommendation, suggestion, direction, or counsel from a physician or qualified nonphysician practitioner (NPP) at the request of another physician or appropriate source. Section 1834(m) of the Social Security Act includes “professional consultations” in the definition of telehealth services. Inpatient or emergency department consultations furnished via telehealth can facilitate the provision of certain services and/or medical expertise that might not otherwise be available to a patient located at an originating site. The use of a telecommunications system may substitute for an in-person encounter for emergency department or initial and follow-up inpatient consultations.
Medicare A/B MACs (B) pay for reasonable and medically necessary inpatient or emergency department telehealth consultation services furnished to beneficiaries in hospitals or SNFs when all of the following criteria for the use of a consultation code are met:
- An inpatient or emergency department consultation service is distinguished from other inpatient or emergency department evaluation and management (E/M) visits because it is provided by a physician or qualified nonphysician practitioner (NPP) whose opinion or advice regarding evaluation and/or management of a specific problem is requested by another physician or other appropriate source. The qualified NPP may perform consultation services within the scope of practice and licensure requirements for NPPs in the State in which he/she practices;
- A request for an inpatient or emergency department telehealth consultation from an appropriate source and the need for an inpatient or emergency department telehealth consultation (i.e., the reason for a consultation service) shall be documented by the consultant in the patient’s medical record and included in the requesting physician or qualified NPP’s plan of care in the patient’s medical record; and
- After the inpatient or emergency department telehealth consultation is provided, the consultant shall prepare a written report of his/her findings and recommendations, which shall be provided to the referring physician.
The intent of an inpatient or emergency department telehealth consultation service is that a physician or qualified NPP or other appropriate source is asking another physician or qualified NPP for advice, opinion, a recommendation, suggestion, direction, or counsel, etc. in evaluating or treating a patient because that individual has expertise in a specific medical area beyond the requesting professional’s knowledge.
Unlike inpatient or emergency department telehealth consultations, the majority of subsequent inpatient hospital, emergency department and nursing facility care services require in-person visits to facilitate the comprehensive, coordinated, and personal care that medically volatile, acutely ill patients require on an ongoing basis.
Subsequent hospital care services are limited to one telehealth visit every 3 days. Subsequent nursing facility care services are limited to one telehealth visit every 30 days. Beginning with dates of service on and after January 1, 2021, the limit for nursing facility care services is one telehealth visit every 14 days.
Telehealth Consultation Services, Emergency Department or Initial Inpatient Defined
Emergency department or initial inpatient telehealth consultations are furnished to beneficiaries in hospitals or SNFs via telehealth at the request of the physician of record, the attending physician, or another appropriate source. The physician or practitioner who furnishes the emergency department or initial inpatient consultation via telehealth cannot be the physician of record or the attending physician, and the emergency department or initial inpatient telehealth consultation would be distinct from the care provided by the physician of record or the attending physician. Counseling and coordination of care with other providers or agencies is included as well, consistent with the nature of the problem(s) and the patient’s needs. Emergency department or initial inpatient telehealth consultations are subject to the criteria for emergency department or initial inpatient telehealth consultation services, as described in section 190.3.1 of this chapter.
Payment for emergency department or initial inpatient telehealth consultations includes all consultation related services furnished before, during, and after communicating with the patient via telehealth. Pre-service activities would include, but would not be limited to, reviewing patient data (for example, diagnostic and imaging studies, interim labwork) and communicating with other professionals or family members. Intra-service activities must include the three key elements described below for each procedure code. Post-service activities would include, but would not be limited to, completing medical records or other documentation and communicating results of the consultation and further care plans to other health care professionals. No additional E/M service could be billed for work related to an emergency department or initial inpatient telehealth consultation.
Emergency department or initial inpatient telehealth consultations could be provided at various levels of complexity. (see manual for details).
Although emergency department or initial inpatient telehealth consultations are specific to telehealth, these services must be billed with POS 02 to identify the telehealth technology used to provide the service.
Follow-Up Inpatient Telehealth Consultations Defined
Follow-up inpatient telehealth consultations are furnished to beneficiaries in hospitals or SNFs via telehealth to follow up on an initial consultation, or subsequent consultative visits requested by the attending physician. The initial inpatient consultation may have been provided in-person or via telehealth.
Follow-up inpatient telehealth consultations include monitoring progress, recommending management modifications, or advising on a new plan of care in response to changes in the patient’s status or no changes on the consulted health issue. Counseling and coordination of care with other providers or agencies is included as well, consistent with the nature of the problem(s) and the patient’s needs.
The physician or practitioner who furnishes the inpatient follow-up consultation via telehealth cannot be the physician of record or the attending physician, and the follow-up inpatient consultation would be distinct from the follow-up care provided by the physician of record or the attending physician. If a physician consultant has initiated treatment at an initial consultation and participates thereafter in the patient’s ongoing care management, such care would not be included in the definition of a follow-up inpatient consultation. Follow-up inpatient telehealth consultations are subject to the criteria for inpatient telehealth consultation services, as described in section 190.3.1 of this chapter.
Payment for follow-up inpatient telehealth consultations includes all consultation related services furnished before, during, and after communicating with the patient via telehealth. Pre-service activities would include, but would not be limited to, reviewing patient data (for example, diagnostic and imaging studies, interim labwork) and communicating with other professionals or family members. Intra-service activities must include at least two of the three key elements described below for each procedure code. Post-service activities would include, but would not be limited to, completing medical records or other documentation and communicating results of the consultation and further care plans to other health care professionals. No additional evaluation and management service could be billed for work related to a follow-up inpatient telehealth consultation.
Follow-up inpatient telehealth consultations could be provided at various levels of complexity (see manual for details).
Although follow-up inpatient telehealth consultations are specific to telehealth, these services must be billed with POS 02 to identify the telehealth technology used to provide the service.
ESRD-Related Services as a Telehealth Service
The ESRD-related services included in the monthly capitation payment (MCP) with 2 or 3 visits per month and ESRD-related services with 4 or more visits per month may be paid as Medicare telehealth services. However, at least 1 visit must be furnished face-to-face “hands on” to examine the vascular access site by a physician, clinical nurse specialist, nurse practitioner, or physician assistant. An interactive audio and video telecommunications system may be used for providing additional visits required under the 2-to-3 visit MCP and the 4-or-more visit MCP. The medical record must indicate that at least one of the visits was furnished face-to-face “hands on” by a physician, clinical nurse specialist, nurse practitioner, or physician assistant.
Clinical Criteria: The visit, including a clinical examination of the vascular access site, must be conducted face-to-face “hands on” by a physician, clinical nurse specialist, nurse practitioner or physician’s assistant. For additional visits, the physician or practitioner at the distant site is required, at a minimum, to use an interactive audio and video telecommunications system that allows the physician or practitioner to provide medical management services for a maintenance dialysis beneficiary. For example, an ESRD-related visit conducted via telecommunications system must permit the physician or practitioner at the distant site to perform an assessment of whether the dialysis is working effectively and whether the patient is tolerating the procedure well (physiologically and psychologically). During this assessment, the physician or practitioner at the distant site must be able to determine whether alteration in any aspect of the beneficiary’s prescription is indicated, due to such changes as the estimate of the patient’s dry weight.
Subsequent Hospital Care Services and Subsequent Nursing Facility Care Services as Telehealth Services
Subsequent hospital care services are limited to one telehealth visit every 3 days. The frequency limit of the benefit is not intended to apply to consulting physicians or practitioners, who should continue to report initial or follow-up inpatient telehealth consultations using the applicable HCPCS G-codes.
Similarly, subsequent nursing facility care services are limited to one telehealth visit every 30 days. Beginning with dates of service on and after January 1, 2021, the limit for nursing facility care services is one telehealth visit every 14 days. Furthermore, subsequent nursing facility care services reported for a Federally-mandated periodic visit under 42 CFR 483.40(c) may not be furnished through telehealth. The frequency limit of the benefit is not intended to apply to consulting physicians or practitioners, who should continue to report initial or follow-up inpatient telehealth consultations using the applicable HCPCS G-codes.
Inpatient telehealth consultations are furnished to beneficiaries in hospitals or skilled nursing facilities via telehealth at the request of the physician of record, the attending physician, or another appropriate source. The physician or practitioner who furnishes the initial inpatient consultation via telehealth cannot be the physician or practitioner of record or the attending physician or practitioner, and the initial inpatient telehealth consultation would be distinct from the care provided by the physician or practitioner of record or the attending physician or practitioner. Counseling and coordination of care with other providers or agencies is included as well, consistent with the nature of the problem(s) and the patient’s needs. Initial and follow-up inpatient telehealth consultations are subject to the criteria for inpatient telehealth consultation services, as described in section 190.3 of this chapter.
Diabetes Self-Management Training as a Telehealth Service
Individual and group DSMT services may be paid as a Medicare telehealth service. Before 03-11-2016, this manual provision required that 1 hour of the 10 hour DSMT benefit’s initial training must be furnished in-person to allow for effective injection training. Because injection training is not always clinically indicated, we are revising this provision to permit all 10 hours of the initial training and the two (2) hours of annual follow-up training to be furnished via telehealth in those cases when injection training is not applicable. The in-person injection training, when provided, may be furnished through either individual or group DSMT services. By reporting place of service (POS) 02 or the – GT or –GQ modifier with HCPCS code G0108 (Diabetes outpatient self-management training services, individual, per 30 minutes) or G0109 (Diabetes outpatient self-management training services, group session (2 or more), per 30 minutes), the distant site practitioner attests that the beneficiary has received or will receive 1 hour of in-person DSMT services for purposes of injection training when it is indicated during the year following the initial DSMT service or any calendar year’s 2 hours of follow-up training.
Payment for Telehealth for Individuals with Acute Stroke
Section 50325 of the Bipartisan Budget Act of 2018 amended section 1834(m) of the Act by adding a new paragraph (6) that provides special rules for telehealth services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke (acute stroke telehealth services), as determined by the Secretary. Specifically, section 1834(m)(6)(A) of the Act removes the restrictions on the geographic locations and the types of originating sites where acute stroke telehealth services can be furnished. Section 1834(m)(6)(B) of the Act specifies that acute stroke telehealth services can be furnished in any hospital, critical access hospital, mobile stroke units (as defined by the Secretary), or any other site determined appropriate by the Secretary, in addition to the current eligible telehealth originating sites. Section 1834(m)(6)(C) of the Act limits payment of an originating site facility fee to acute stroke telehealth services furnished in sites that meet the usual telehealth restrictions under section 1834(m)(4)(C) of the Act. These are identified in Section 190.1 of this chapter.
Effective for claims with dates of service on and after January 1, 2019, contractors shall accept new informational HCPCS modifier G0 (G zero), to be used to identify Telehealth services furnished for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke. Modifier G0 is valid for all:
- Telehealth distant site codes billed with Place of Service (POS) code 02 or Critical Access Hospitals, CAH method II (revenue codes 096X, 097X, or 098X); or
- Telehealth originating site facility fee, billed with HCPCS code Q3014
Editing of Telehealth Claims
Medicare telehealth services (as listed in section 190.3) are billed with POS 02 and 10. The contractor shall approve covered telehealth services if the physician or practitioner is licensed under State law to provide the service. Contractors must familiarize themselves with licensure provisions of States for which they process claims and disallow telehealth services furnished by physicians or practitioners who are not authorized to furnish the applicable telehealth service under State law. For example, if a nurse practitioner is not licensed to provide individual psychotherapy under State law, he or she would not be permitted to receive payment for individual psychotherapy under Medicare. The contractor shall install edits to ensure that only properly licensed physicians and practitioners are paid for covered telehealth services.
Contractors shall deny telehealth services if the physician or practitioner is not eligible to bill for them.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 169-174, 181, (Accessed Mar. 2025).
Since telehealth dialysis services are limited to renal dialysis services for home dialysis patients telehealth related to renal dialysis services is not available for beneficiaries with AKI.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 11: End Stage Renal Disease (ESRD), 3/1/19, pg. 60, (Accessed Mar. 2025).
Medicare Part B pays for covered telehealth services included on the telehealth list when furnished by an interactive telecommunications system if the following conditions are met, except that for the duration of the Public Health Emergency as defined in § 400.200 of this chapter, Medicare Part B pays for office and other outpatient visits, professional consultation, psychiatric diagnostic interview examination, individual psychotherapy, pharmacologic management and end stage renal disease related services included in the monthly capitation payment furnished by an interactive telecommunications system if the following conditions are met.
clinical psychologist and a clinical social worker, a marriage and family therapist (MFT), and a mental health counselor (MHC) may bill and receive payment for individual psychotherapy via a telecommunications system, but may not seek payment for medical evaluation and management services.
The physician visits required under § 483.40(c) of this title may not be furnished as telehealth services.
The distant site practitioner who reports the DSMT services may bill and receive payment when a professional furnishes injection training for an insulin-dependent patient using interactive telecommunications technology when such training is included as part of the DSMT plan of care referenced at § 410.141(b)(2).
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2025).
Process for adding or deleting services. Except as otherwise provided in this paragraph (f), changes to the list of Medicare telehealth services are made through the annual physician fee schedule rulemaking process. During the Public Health Emergency, as defined in § 400.200 of this chapter, we will use a subregulatory process to modify the services included on the Medicare telehealth list during the Public Health Emergency, taking into consideration infection control, patient safety, and other public health concerns resulting from the emergency. CMS maintains the list of services that are Medicare telehealth services under this section, including the current HCPCS codes that describe the services on the CMS website.
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2025).
List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth is available on the CMS website. Find the complete List of Telehealth Services by downloading the ZIP and opening the Excel or text files.
SOURCE: CMS Telehealth List Year, Updated for 2025. (Accessed Mar. 2025).
See Table 12 (page 132) in the 2025 Physician Fee Schedule for additional codes for 2025.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
For most non-behavioral or mental telehealth, you must use 2-way, interactive, audio-video technology. Section 4113 of the Consolidated Appropriations Act, 2023 allows you to use audio-only telehealth for some non-behavioral or mental telehealth through December 31, 2024.
Starting January 1, 2025, you may use 2-way, interactive, audio-only technology if the distant site provider is technically capable of using an audio-video telehealth system and the patient is in their home but isn’t capable of, or doesn’t consent to, using video technology.
Through December 31, 2024:
- You may use telehealth to conduct hospice care eligibility recertification
- For behavioral or mental telehealth, you don’t have to conduct an in-person visit within 6 months of the initial telehealth visit or annually thereafter
- We’ve extended the Acute Hospital Care at Home Program, which heavily relies on telehealth for hospitals to provide inpatient services, including routine services, outside the hospital
Starting January 1, 2023, you may voluntarily report the use of telehealth technology in providing home health (HH) services on HH payment claims. See MLN Matters Article MM12805 for more information.
You must submit the use of telecommunications technology on the HH claims using the following 3 HCPCS codes:
- G0320: Home health services you furnish using synchronous telehealth you render via real-time audio video telehealth
- G0321: Home health services you furnish using synchronous telehealth you render via telephone or another real-time, interactive, audio-only telehealth
- G0322: The collection of physiologic data the patient digitally stores or transmits to the HH agency
See fact sheet for additional details.
Medicare breaks down telehealth services into 2 categories—permanent and provisional. We aren’t recategorizing any codes from provisional to permanent for CY 2025 because we’ll conduct a comprehensive analysis of all provisional codes. Based on several telehealth provisions in the CY 2025 PFS final rule, we’ve added these services to the Medicare Telehealth Services List:
- Caregiver training services, which we’re adding on a provisional basis
- CPT codes 97550, 97551, 97552, 96202, and 96203
- HCPCS codes G0539–G0543
- Pre-Exposure Prophylaxis (PrEP) counseling services, which we’re adding permanently
- HCPCS code G0011
- HCPCS code G0013
Safety planning intervention services for patients in crisis (HCPCS code G0560), which we’re adding permanently
We’ll pay for the new CPT code 98016, which describes short virtual check-ins, instead of HCPCS code G2012. We’ll delete G2012 from the PFS, effective January 1, 2025. Starting January 1, 2025, Opioid Treatment Programs (OTPs) may provide these services through telecommunication technology if all requirements are met and the use of these technologies is permitted under the applicable SAMHSA and DEA requirements when the services are provided:
- Periodic assessments via audio-only telecommunications
- Intake add-on code via two-way audio-video communications technology when billed for the initiation of treatment with methadone (HCPCS code G2076) if the OTP determines that an adequate evaluation of the patient can be accomplished via audio-visual telehealth platform
We’ll temporarily suspend telehealth frequency limitations on subsequent inpatient (CPT codes 99231, 99232, 99233, 99307, 99308, 99309, and 99310) and nursing facility visits and on critical care consultations (HCPCS codes G0508 and G0509) through CY 2025
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Communication Technology-Based Services (CTBS)
CMS makes separate payment for brief communication technology-based services. This includes ‘brief communication technology-based service, e.g. virtual check-in’ by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, 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; 5–10 minutes of medical discussion). The code (G2012) allows real-time audio-only telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission. The service is limited to established patients. [See below for changes to G2012]
Interprofessional consultations are reimbursable by CMS as part of their CTBS services (CPT codes include 99451, 99452, 99446, 99447, 99448, and 99449). Cost sharing will apply. These interprofessional services may be billed only by practitioners that can bill Medicare independently for evaluation and management services. Includes telephone and internet assessments.
CTBS services are not regarded by CMS as telehealth.
See also:
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Mar. 2025).
CMS has finalized a proposal to pay separately for PT Coe 98016 in lieu of HCPCS code G2012.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
CMS has finalized a process for which services will be added to the permanently eligible telehealth services list. In the new process, a suggested code would either be made permanent, provisional or rejected. See CY 2024 Physician Fee Schedule or the CMS webpage that describes the process for more details.
CMS is finalizing its proposal that would allow practitioners who can “appropriately report DSMT services furnished in person by the DSMT entity…to report DSMT services via telehealth by the DSMT entity, including when the services are performed by others as part of the DSMT entity.”
Additionally, flexibilities for the Medicare Diabetes Prevention Program (MDPP) will be extended for an additional four years. Among the flexibilities is the ability to provide distance learning virtually.
Frequency limitations on subsequent in-patient visits, subsequent skilled nursing facility visits and critical care consultations are removed for CY 2024.
Telehealth Injection Training for Insulin-Dependent – Providers can use telehealth to provide the full initial 10 hours or annual 2 hours of insulin injection-training that is required for insulin dependent beneficiaries to take place via telehealth. CMS clarified that only physicians and those nonphysician practitioners listed in section 1842(b)(18)(C) may bill and hospitals and pharmacies are not included.
Periodic Assessments for Opioid Use Disorder (OUD) by Opioid Treatment Provider (OTP) – CMS will extend periodic assessments by OTPs to the end of 2024. The audio-only option will only be available if video is not and to the extent audio-only is permitted by SAMHSA and Drug Enforcement Administration (DEA) and all other relevant requirements.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
We may cover these behavioral health and wellness services:
- Interactive telecommunications, including 2-way, interactive audio-only technology to diagnose, evaluate, or treat certain mental health or SUDs using telehealth services if the patient is in their home
- Hospital clinical staff must have the capability to provide 2-way, interactive, audio-video technology services but may use audio-only technology given an individual patient’s technological limitations, abilities, or preferences
- You can provide telehealth using 2-way, interactive, audio-only technology through December 31, 2024
- Telehealth services provided to people in their homes will be paid at the non-facility PFS rate through December 31, 2024
- Marriage and family therapist (MFT) services (also available through telehealth)
- Mental health counselor (MHC) services (also available through an acceptable telehealth mental health disorder service site)
- Addiction counselors or alcohol and drug counselors who meet the applicable MHC requirements can enroll in Medicare as MHCs
- SUD treatment in a patient’s home (an acceptable telehealth substance use treatment or a co-occurring mental health disorder service site)
Beginning in 2025, in-person visit requirements will apply for mental health services provided by telehealth. This includes a required in-person visit within the 6 months before the initial telehealth treatment as well as the required subsequent in-person visits at least every 12 months.
We’ll continue to define direct supervision to permit the immediate availability of the supervising practitioner through real-time audio and visual interactive telecommunications through December 31, 2024.
The regulations at 42 CFR 410.78(b)(3)(xiv) describe 2 exceptions to the in-person requirements that take effect on January 1, 2025:
- Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate
- Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability.
The telehealth policies described above also apply to Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
Exceptions to the in-person visit requirement require a clear justification documented in the patient’s medical record. Hospitals must also document that patients have a regular source of general medical care and can get any needed point-of-care testing, including vital sign monitoring and lab studies.
We created 3 Outpatient Prospective Payment System (OPPS)-specific HCPCS codes to describe that the patient must be in their home and that no associated professional service is billed under the PFS. Hospital staff must be licensed to provide these services consistent with all applicable state scope of practice laws. We exempt these services from having staff physically located in the hospital or outpatient department when providing services remotely using communication technology. See booklet for list of codes.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Learning Network Booklet 1986542, Medicare & Mental Health Coverage, Jul. 2024, (Accessed Mar. 2025).
Q3: Can outpatient therapy, diabetes self-management training and medical nutrition therapy services be furnished remotely by hospital staff to beneficiaries in their homes?
A3: As we explained in the CY 2025 OPPS/ASC final rule with comment period, we have generally aligned payment policies for outpatient therapy services, diabetes self-management training (DSMT) and medical nutrition therapy (MNT) services furnished remotely by hospital staff to beneficiaries in their homes with policies for Medicare telehealth services. We noted in the CY 2025 OPPS/ASC proposed rule that, to the extent therapists and DSMT and MNT practitioners continue to be distant site practitioners for purposes of Medicare telehealth services, we anticipated aligning our policy for these services with policies under the Physician Fee Schedule (PFS) and continuing to make payment to the hospital for these services when furnished by hospital staff. When the CY 2025 OPPS/ASC final rule was issued, the flexibility to allow an expanded range of practitioners to be eligible to furnish Medicare telehealth services, which included physical therapists (PTs), occupational therapists (OTs), and speech language pathologists (SLPs), was set to expire at the end of CY 2024. Consequently we stated that we would no longer pay for outpatient therapy, DSMT, and MNT services when furnished remotely by hospital staff to beneficiaries in their homes beginning in CY 2025, but we also noted that continuing to align our policies for outpatient therapy, DSMT, and MNT services when furnished by hospital staff with the Medicare telehealth policies that apply when these services are billed by the same clinicians but in private practice ensures clarity and consistency for providers and beneficiaries.
The American Relief Act, 2025 extended the expansion of the types of practitioners eligible to furnish Medicare telehealth services through March 31, 2025, thus enabling PTs, OTs, and SLPs to continue furnishing telehealth services through that date. CMS is continuing to align our requirements for payment for services furnished remotely by hospital staff to beneficiaries in their homes, including remotely furnished outpatient therapy services, DSMT, and MNT services, with requirements for Medicare telehealth services. Therefore, through March 31, 2025, hospitals can continue to bill for these services when furnished remotely by hospital staff to beneficiaries in their homes.
Q9: Are there frequency limitations for subsequent inpatient and nursing facility visits and critical care consultations?
A9: In the CY 2025 PFS final rule, we established that through December 31, 2025, we are continuing to suspend the application of telehealth frequency limits on subsequent inpatient and nursing facility visits and critical care consultations.
Q12: What does the “provisional” or “permanent” designation mean on the Medicare Telehealth Services List?
A12: In the CY 2024 PFS final rule (88 FR 78861 through 78866), we implemented a revised 5-step process for making additions, deletions, and changes to the Medicare Telehealth Services List (5-step process), beginning for the CY 2025 Medicare Telehealth Services List. Rather than categorizing a service as “Category 1” or “Category 2,” each service is now assigned a “permanent” or “provisional” status. A service is assigned a “provisional” status if available evidence does not yet demonstrate that the service is definitively of clinical benefit, but there is enough evidence to suggest that further study may demonstrate such benefit. The 5-step process review criteria are set forth in the CY 2024 PFS final rule (88 FR 78861 through 78866) and listed at https://www.cms.gov/medicare/coverage/telehealth/criteria-request.
Q13: Do services with a “provisional” designation expire each calendar year?
A13: No, there is no time limitation for services designated as “provisional” on the Medicare Telehealth Services List . We did not consider for CY 2025 whether to recategorize provisional codes as permanent because we intend to conduct a comprehensive evaluation of all Medicare telehealth services with provisional status. Services included on the Medicare Telehealth Services List with provisional status will remain on the list. We anticipate addressing these services in future rulemaking.
Q14: How do I request a change to the Medicare Telehealth Services List?
A14: Requests for changes to the Medicare Telehealth Services List must be received by CMS by February 10 of a year to be considered by CMS and addressed in PFS rulemaking for the following calendar year. Each request to add a service to the Medicare Telehealth Services List must include any supporting documentation the requester wishes us to consider as we review the request. Because we use the annual PFS rulemaking process to make changes to the Medicare Telehealth Services List, requesters are advised that any information submitted as part of a request is subject to public disclosure for this purpose. For more information on submitting a request to add or modify services on the Medicare Telehealth Services List, including where to send these requests, and to view the current Medicare Telehealth Services List, see our website at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/index.html.
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
Indian Health Services
The services that may be paid to IHS physicians and practitioners under the MPFS are as follows:
- Payment for telehealth services under Medicare Part B are covered as described in Pub. 100-04, Medicare Claims Processing Manual, Chapter12, §190.
For background on the telehealth benefit, see Chapter 12, §190.1 in this manual. For more information on the payment of Telehealth services, see Chapter 15 of the Benefit Policy Manual. Telehealth services fall into two categories: an originating site facility service in which the beneficiary is presented to the distant site practitioner, and a distant site service which is generally some type of professional consultation.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 19: Indian Health Services, 5/20/22, (Accessed Mar. 2025).
Home Health Services
The face-to-face encounter can be performed via a telehealth service, in an approved originating site. …
Section 1895(e) governs the home health prospective payment system (PPS) and provides that telehealth services are outside the scope of the Medicare home health benefit and home health PPS.
This provision does not provide coverage or payment for Medicare home health services provided via a telecommunications system. The law does not permit the substitution or use of a telecommunications system to provide any covered home health services paid under the home health PPS, or any covered home health service paid outside of the home health PPS. As stated in 42 CFR 409.48(c), a visit is an episode of personal contact with the beneficiary by staff of the home health agency (HHA), or others under arrangements with the HHA for the purposes of providing a covered service. The provision clarifies that there is nothing to preclude an HHA from adopting telemedicine or other technologies that they believe promote efficiencies, but there is no separate reimbursement for those technologies under the Medicare home health benefit. However, Medicare does recognize services furnished via telecommunications technology (see section 80.10) as an allowed administrative cost on Medicare cost reports if telecommunications technology is used by the HHA to augment the care planning process, and the technology is indicated on the plan of care.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 7: Home Health Services, 12/21/23, (Accessed Mar. 2025).
As of January 1, 2010, CMS no longer recognizes consultation codes for Medicare payment, except for inpatient telehealth consultation HCPCS G-codes. Instead, physicians and qualified nonphysician practitioners are instructed to bill a new or established patient office/outpatient visit CPT code or appropriate hospital or nursing facility care code. For further detail regarding reporting services that would otherwise be described by the CPT consultation codes (99241-99245 and 99251-99255), see Pub. 100-04, Medicare Claims Processing Manual, chapter 12, section 30.6. For detailed instructions regarding reporting telehealth consultation services and other telehealth services, see Pub. 100-04, chapter 12, section 190.3.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 15: Covered Medical and Other Health Services, 10/4/24, pg. 10, (Accessed Mar. 2025).
Aligning with recent regulations previously adopted by the Substance Abuse and Mental Health Services Administration (SAMHSA), CMS finalized the following: …
- Allow OTP intake add-on code (G2076) to be furnished by live video when it is being billed for the initiation of treatment with methadone.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
Diabetes Self Management Training
Providers may deliver DSMT as a telehealth service when a registered dietitian, nutrition professional, physician, nurse practitioner (NP), physician assistant (PA), or clinical nurse specialist (CNS) serves as the distant site practitioner. These practitioners can bill and receive payment for DSMT services when they:
- Act on behalf of other qualified personnel who deliver the DSMT services within an authorized DSMT entity.
- Provide injection training for insulin-dependent patients through interactive telehealth technology, as long as this training is part of the patient’s DSMT plan of care.
CMS emphasizes that telehealth-based DSMT injection training must align with recognized clinical standards, guidelines, or best practices to ensure patient safety and efficacy.
SOURCE: Center for Medicare and Medicaid Services, Medicare Learning Network Factsheet: Provider Information on Medicare Diabetes Self-Management Training, Sept. 2024, (Accessed Mar. 2025).
Section 4113 of the CAA, 2023 expanded the range of practitioners eligible to furnish telehealth services only through CY 2024, which included PTs, OTs, and SLPs. Beginning January 1, 2025, these practitioners will no longer be able to bill for Medicare telehealth services. Consequently, beginning January 1, 2025, we likewise will no longer pay for outpatient therapy, DSMT, and MNT services when furnished remotely by hospital staff to beneficiaries in their homes.
SOURCE: Center for Medicare and Medicaid Services, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems CY 2025 Rule, CMS-1809-FC, 11/27/24, (Accessed Mar. 2025).
Hospitals
Given the similarities between the new telemedicine E/M code set and the office/outpatient E/M code set, we believe that the telemedicine E/M codes fall within the scope of the hospital outpatient clinic visit policy because the predecessor codes (the office/outpatient E/M code set) would be reported by hospitals using HCPCS code G0463. Under the hospital outpatient clinic visit policy, the CPT codes describing office/outpatient E/M visits are not recognized under the OPPS and instead hospitals report HCPCS code G0463 (Hospital outpatient clinic visit for assessment and management of a patient) when billing for the facility costs associated with an outpatient E/M visit. Therefore, we proposed to not recognize the telemedicine E/M code set under OPPS. We invited comment on the hospital resources associated with the telemedicine E/M services, particularly any resource costs that would not be included in the payment for HCPCS code G0463. We also invited comment, should CMS finalize separate payment for these telemedicine E/M codes under the PFS, on the resource costs that would be associated with these services for hospitals and whether we should develop separate coding to describe the resource costs associated with a telemedicine E/M service.
We thank commenters for the additional information and may consider this issue, including any refinements to our clinic visit policy, for future rulemaking. As we are not finalizing payment for the telemedicine E/M CPT codes under the PFS, we do not believe there is a programmatic need to recognize these codes for payment under the OPPS. After consideration of the public comments we received, we are finalizing our proposal not to recognize the telemedicine E/M code set under the OPPS as proposed.
SOURCE: Center for Medicare and Medicaid Services, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems CY 2025 Rule, CMS-1809-FC, 11/27/24, (Accessed Mar. 2025).
ELIGIBLE PROVIDERS
Temporary Policy – Ends Dec. 31, 2024
The term “practitioner” has the meaning given that term in section 1395u(b)(18)(C) of this title and, in the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, for the period beginning on the first day after the end of such emergency period and ending on September 30, 2025, shall include a qualified occupational therapist (as such term is used in section 1395x(g) of this title), a qualified physical therapist (as such term is used in section 1395x(p) of this title), a qualified speech-language pathologist (as defined in section 1395x(ll)(4)(A) of this title), and a qualified audiologist (as defined in section 1395x(ll)(4)(B) of this title).
…
During the emergency period described in section 1320b–5(g)(1)(B) of this title and, in the case that such emergency period ends before December 31, 2024, during the period beginning on the first day after the end of such emergency period and ending on September 30, 2025—
- the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligible telehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same location as the beneficiary;
- the amount of payment to a Federally qualified health center or rural health clinic that serves as a distant site for such a telehealth service shall be determined under subparagraph (B); and
- for purposes of this subsection—
- the term “distant site” includes a Federally qualified health center or rural health clinic that furnishes a telehealth service to an eligible telehealth individual; and
- the term “telehealth services” includes a rural health clinic service or Federally qualified health center service that is furnished using telehealth to the extent that payment codes corresponding to services identified by the Secretary under clause (i) or (ii) of paragraph (4)(F) are listed on the corresponding claim for such rural health clinic service or Federally qualified health center service.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
Beginning on or after January 1, 2023, HHAs may voluntarily report the use of telecommunications technology in the provision of home health services on claims. This information is required on home health claims beginning on July 1, 2023. HHAs shall submit the use of telecommunications technology when furnishing home health services, on the home health claim via three G-codes.
- G0320: home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
- G0321: home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
- G0322: the collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (i.e., remote patient monitoring).
HHAs shall submit services furnished via telecommunications technology in line item detail and with covered charges. Each service must be reported as a separately dated line under the appropriate revenue code for each discipline furnishing the service. Two occurrences of G0320 or G0321 on the same day for the same revenue code shall be reported as separate line items with the same date of service and with service units reporting 1. Services furnished via telecommunications technology are not considered by Medicare systems when enforcing requirements for matching visit dates on home health claims.
Claims with no billable visits are not submitted to Medicare, including claims for billing periods where only telehealth services are provided.
Telehealth services with HCPCS codes G0320 or G0321 are reported with units of 1.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 10: Home Health Agency Billing, 5/2/24, pg. 62, (Accessed Mar. 2025).
Inpatient Rehabilitation Facility (IRF) Flexibilities Issued on March 30, 2020
On March 30, 2020, CMS issued the interim final rule “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency” (CMS-1744-IFC). …
This interim final rule also revises the physician supervision requirement in 42 CFR § 412.622(a)(3)(iv) and § 412.29(e) to permit physician visits in the IRF required under these provisions to be conducted via telehealth to safeguard the health and safety of Medicare beneficiaries and the rehabilitation physicians treating them during the PHE. Contractors shall allow rehabilitation physicians to use telehealth services as defined in section 1834(m)(4)(F) of the Act to conduct the required 3 physician visits per week during the PHE for the COVID-19 pandemic.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 1: Inpatient Hospital Services Covered Under Part A, 8/6/21, pg. 40, (Accessed Mar. 2025).
Permanent Policy
Subject to paragraph (8), the Secretary shall pay to a physician or practitioner located at a distant site that furnishes a telehealth service to an eligible telehealth individual an amount equal to the amount that such physician or practitioner would have been paid under this subchapter had such service been furnished without the use of a telecommunications system.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
The physician or practitioner at the distant site must be licensed to furnish the service under State law. The physician or practitioner at the distant site who is licensed under State law to furnish a covered telehealth service described in this section may bill, and receive payment for, the service when it is delivered via a telecommunications system.
The practitioner at the distant site is one of the following:
- A physician
- A nurse practitioner
- Physician Assistant
- A clinical nurse specialist
- A nurse-midwife
- A clinical psychologist
- A clinical social worker
- A registered dietitian or nutrition professional
- A certified registered nurse anesthetist
- Any distant site practitioner who can appropriately bill for diabetes self-management training services may do so on behalf of others who personally furnish the services as part of the DSMT entity.
- A marriage and family therapist
- A mental health counselor
Clinical psychologist and a clinical social worker, a marriage and family therapist (MFT), and a mental health counselor (MHC) may bill and receive payment for individual psychotherapy via a telecommunications system, but may not seek payment for medical evaluation and management services.
The physician visits required under § 483.40(c) of this title may not be furnished as telehealth services.
The distant site practitioner who reports the DSMT services may bill and receive payment when a professional furnishes injection training for an insulin-dependent patient using interactive telecommunications technology when such training is included as part of the DSMT plan of care referenced at § 410.141(b)(2).
SOURCE: 42 CFR Sec. 410.78, (Accessed Mar. 2025).
A distant site is the location where a physician or practitioner provides telehealth. Before the COVID-19 PHE, only certain types of distant site providers could provide and be paid for telehealth. Through March 31, 2025, all providers eligible to bill Medicare for professional services could provide distant site telehealth.
Through CY 2025, distant site practitioners may continue to use their currently enrolled practice location instead of their home address when providing Medicare telehealth services from their home.
Institutional Billing
Use modifier 95 for outpatient therapy services provided via telehealth by qualified physical therapists, occupational therapists, or speech language pathologists employed by hospitals through December 31, 2024.
We’ll continue to pay Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) for:
- Non-behavioral telehealth medical visit services through March 31, 2025, using the payment amount based on the average amount for all Medicare telehealth services paid under the Physician Fee Schedule (PFS), weighted by volume
- Behavioral health services provided on or after January 1, 2022, under the RHC All-Inclusive Rate (AIR) and FQHC Prospective Payment System (PPS), respectively
We’ll delay the in-person visit requirements for mental health visits that RHCs and FQHCs provide via telecommunications technology through March 31, 2025
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
ESRD Services: The MCP physician, for example, the physician or practitioner who is responsible for the complete monthly assessment of the patient and establishes the patient’s plan of care, may use other physicians and practitioners to furnish ESRD-related visits through an interactive audio and video telecommunications system. The non-MCP physician or practitioner must have a relationship with the billing physician or practitioner such as a partner, employees of the same group practice or an employee of the MCP physician, for example, the non MCP physician or practitioner is either a W-2 employee or 1099 independent contractor. However, the physician or practitioner who is responsible for the complete monthly assessment and establishes the ESRD beneficiary’s plan of care should bill for the MCP in any given month.
A medical professional is not required to present the beneficiary to physician or practitioner at the distant site unless medically necessary. The decision of medical necessity will be made by the physician or practitioner located at the distant site.
The term “distant site” means the site where the physician or practitioner, providing the professional service, is located at the time the service is provided via a telecommunications system.
The payment amount for the professional service provided via a telecommunications system by the physician or practitioner at the distant site is equal to the current fee schedule amount for the service provided. Payment for an office visit, consultation, individual psychotherapy or pharmacologic management via a telecommunications system should be made at the same amount as when these services are furnished without the use of a telecommunications system. For Medicare payment to occur, the service must be within a practitioner’s scope of practice under State law. The beneficiary is responsible for any unmet deductible amount and applicable coinsurance.
As a condition of Medicare Part B payment for telehealth services, the physician or practitioner at the distant site must be licensed to provide the service under state law. When the physician or practitioner at the distant site is licensed under state law to provide a covered telehealth service (i.e., professional consultation, office and other outpatient visits, individual psychotherapy, and pharmacologic management) then he or she may bill for and receive payment for this service when delivered via a telecommunications system.
If the physician or practitioner at the distant site is located in a CAH that has elected Method II, and the physician or practitioner has reassigned his/her benefits to the CAH, the CAH bills its regular A/B/MAC (A) for the professional services provided at the distant site via a telecommunications system, in any of the revenue codes 096x, 097x or 098x. All requirements for billing distant site telehealth services apply.
Medicare Practitioners Who May Bill for Covered Telehealth Services are Listed Below (subject to State law)
- Physician
- Nurse practitioner
- Physician assistant
- Nurse-midwife
- Clinical nurse specialist
- Clinical psychologist*
- Clinical social worker*
- Registered dietitian or nutrition professional
- Certified registered nurse anesthetist
*Clinical psychologists and clinical social workers cannot bill for psychotherapy services that include medical evaluation and management services under Medicare. These practitioners may not bill or receive payment for the following CPT codes: 90805, 90807, and 90809.
As specified in 42 CFR 410.141(e) and stated in Pub. 100-02, Medicare Benefit Policy Manual, chapter 15, section 300.2, individual and group DSMT services may be furnished by a physician, other individual, or entity that furnishes other items or services for which direct Medicare payment may be made and that submits necessary documentation to, and is accredited by a national accreditation organization approved by CMS. However, consistent with the statutory requirements of section 1834(m)(1) of the Act, as provided in 42 CFR 410.78(b)(1) and (b)(2) and stated in section 190.6 of this chapter, Medicare telehealth services, including individual and group DSMT services furnished as a telehealth service, could only be furnished by a physician, PA, NP, CNS, CNM , clinical psychologist, clinical social worker, or registered dietitian or nutrition professional, as applicable.
See manual for additional billing guidance.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 172-179 (Accessed Mar. 2025).
Beginning January 1, 2024, MHCs and MFTs can provide and bill Medicare telehealth services. Exceptions to the in-person visit requirement require a clear justification documented in the patient’s medical record. Hospitals must also document that patients have a regular source of general medical care and can get any needed point-of-care testing, including vital sign monitoring and lab studies.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Learning Network Booklet 1986542, Medicare & Mental Health Coverage, Jul. 2024, (Accessed Mar. 2025).
After consideration of public comments, we are finalizing our proposal to add MFTs and MHCs as distant site practitioners for purposes of furnishing telehealth services. We are finalizing our proposed amendments to add MFTs and MHCs to the list of distant site practitioners in the telehealth regulation at § 410.78(b)(2)(xi),(xii).
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
CMS allows Opioid Treatment Programs (OTPs) to use two-way interactive audio-video communication technology, as clinically appropriate, in furnishing substance use counseling and individual and group therapy services. An intake add-on code by live video for the initiation of treatment with buprenorphine, when clinically appropriate and in compliance with other requirement was also added.
SOURCE: CY 2020 Final Physician Fee Schedule. CMS, p. 249, & CY 2023 Final Physician Fee Schedule, CMS, p. 1055, (Accessed Mar. 2025).
Disposition #10 in the CY 2025 Annual Therapy Update was revised to reflect the American Relief Act that extended the ability of PTs, OTs, and SLPs to furnish Telehealth Services through March 31, 2025. Disposition #10 informs therapists about services that are provided remotely or virtually, including the telephone assessment and management services (codes 98966-98968) that were initially added in 2020 during the COVID-19 public health emergency (PHE) and, before being revised, permitted the use of the codes through the end of CY 2024. Since these telephone codes (98966-98968) were added to the list of Telehealth Services, we are clarifying that PTs, OTs, and SLPs may continue to furnish these telephone services, but only through March 31, 2025 (absent additional legislation).
SOURCE: Centers for Medicare and Medicaid Services (CMS), Therapy Services, (Accessed Apr. 2025).
Communication Technology-Based Services
Payment for communication technology-based and remote evaluation services. For communication technology-based and remote evaluation services furnished on or after January 1, 2019, payment to RHCs and FQHCs is at the rate set for each of the RHC and FQHC payment codes for communication technology-based and remote evaluation services.
SOURCE: 42 CFR 405.2464 (Accessed Mar. 2025).
RHCs and FQHCs are not eligible for reimbursement of interprofessional consultation services, as only practitioners that can bill Medicare independently for evaluation and management services are eligible.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Mar. 2025).
New codes created that allow clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors to bill for interprofessional consultations with other practitioners whose practice is similarly limited, as well as with physicians and practitioners who can bill Medicare for E/M services and would use the current CPT codes to bill for interpersonal consultations. These new G codes for behavioral health services were finalized: G0546-G0551. Patient consent must be obtained in advance of the services.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes these services to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.
RHCs and FQHCs may only bill for these services when the medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and does not lead to an RHC or FQHC service within the next 24 hours or at the soonest available appointment, since in those situations, Medicare already pays for the services as part of the RHC or FQHC per-visit payment.
RHCs and FQHCs can bill G0511, G0512, and G0071 alone or with other payable services on an RHC or FQHC claim.
SOURCE: Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, (Accessed Mar. 2025).
What are “virtual communication services” for RHCs and FQHCs?
In the 2019 Physician Fee Schedule (PFS) Final Rule, CMS finalized a policy that, effective January 1, 2019, RHCs and FQHCs can receive payment for virtual communication services when at least 5 minutes of communication technology-based or remote evaluation services are furnished by an RHC or FQHC practitioner to a patient who has had an RHC or FQHC billable visit within the previous year, and both of the following requirements are met:
- The medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and
- The medical discussion or remote evaluation does not lead to an RHC or FQHC visit within the next 24 hours or at the soonest available appointment.
See FAQ for more details.
SOURCE: Virtual Communication Services RHCs and FQHCs FAQs, December 2018, (Accessed Mar. 2025).
RHCs and FQHCs can continue to provide on a temporary basis, for non-behavioral health visits furnished via telecommunication technology under the methodology that has been in place for these services during and after the COVID-19 PHE through December 31, 2024. Specifically, RHCs and FQHCs can continue to bill for RHC and FQHC services furnished using telecommunication technology by reporting HCPCS code G2025 on the claim, including services furnished using audio-only communications technology through December 31, 2025. For payment for non-behavioral health visits furnished via telecommunication technology in CY 2025, the payment amount is based on the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS
SOURCE: CMS Manual System, Transmittal 13133, March 20, 2025, (Accessed Apr. 2025).
Mental Health for FQHCs and RHCs
Revised definition of a ‘mental health visit’ to include encounters furnished through interactive, real-time telecommunications technology, but only when furnishing services for purposes of diagnosis, evaluation or treatment of a mental health disorder.
FQHCs and RHCs will be able to furnish mental health visits to include visits furnished using interactive, real-time telecommunications technology and RHCs and FQHCs can report and be paid for furnishing those visits in the same way they currently do when these services are furnished in-person. RHCs and FQHCs will be paid for mental health visits furnished via telecommunications technology at the same rate they are paid for in-person mental health visits (that is, the AIR or FQHC PPS).
There must be an in-person mental health service furnished within 6 months prior to the furnishing of the telecommunications service and that in general, there must be an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders. This applies only to patients receiving services at home. If the patient and practitioner consider the risks and burdens of an in-person service and agree that, on balance, these outweigh the benefits, and the practitioner documents the basis for that decision in the patient’s medical record, then the in-person visit requirement is not applicable for that 12-month period.
In person requirement delayed under Medicare until on or after October 1, 2025.
SOURCE: CY 2022 Physician Fee Schedule, CMS, p. 214-215 & delay in implementation. (Accessed Mar. 2025).
CMS will continue to allow on a temporary basis payment to FQHCs and RHCs for non-behavioral health visits that use telecommunications technology. This temporary policy would allow other non-mental health services to be provided via telehealth by FQHCs and RHCs through 2025 by continuing to use the code G2025 to bill. CMS notes that this will help ensure continuation of services if the current telehealth waivers do expire on December 31, 2024. It should be noted that in calculating the amount to be reimbursed for G2025, CMS will be basing it on the average amount for all PFS telehealth services on the telehealth list, weighted by the volume for those services reported under the PFS.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
RHCs and FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. You may use audio-only technology in situations when your patient can’t access or doesn’t consent to use audio-video technology. You can report and get paid in the same way as in-person visits.
- Audio-video visits: Use modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System).
- Audio-only visits: Use new service-level modifier FQ or 93.
These in-person visit requirements apply only to a patient getting mental health visits via telecommunications at home:
- There must be an in-person mental health visit 6 months before the telecommunications visit
- In general, there must be an in-person mental health visit at least every 12 months while the patient is getting services from you via telecommunications to diagnose, evaluate, or treat mental health disorders
NOTE: Section 4113 of the Consolidated Appropriations Act (CAA), 2023, delayed the in-person visit requirements under Medicare for mental health visits that RHCs and FQHCs provide via telecommunications technology. For RHCs and FQHCs, we won’t require in-person visits until January 1, 2025.
CMS will allow for limited exceptions to the requirement for an in-person visit every 12 months based on patient circumstances in which the risks and burdens of an in-person visit may outweigh the benefit. These include, but aren’t limited to, when:
- An in-person visit is likely to cause disruption in service delivery or has the potential to worsen the patient’s condition
- The patient getting services is in partial or full remission and only needs maintenance level care
- The clinician’s professional judgment says that the patient is clinically stable and that an in-person visit has the risk of worsening the patient’s condition, creating undue hardship on self or family
- The patient is at risk of withdrawing from care that’s been effective in managing the illness
With proper documentation, the in-person visit requirement isn’t applicable for that 12-month period. You must document the circumstance in the patient’s medical record.
SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Mar. 2025).
FQHCs/RHCs
A mental health visit is a medically-necessary face-to-face encounter between an RHC or FQHC patient and an RHC or FQHC practitioner during which time one or more RHC or FQHC mental health services are rendered. Effective January 1, 2022, a mental health visit is a face-to-face encounter or an encounter furnished using interactive, real-time, audio and video telecommunications technology or audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
Beginning January 1, 2025, there must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.
RHCs and FQHCs are instructed to append modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) in instances where the mental health visit was furnished using audio-video communication technology and to append modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) in cases where the service was furnished using audio-only communication.
Mental health services that qualify as stand-alone billable visits in an FQHC are listed on the FQHC center website, http://www.cms.gov/Center/Provider-Type/FederallyQualified-Health-Centers-FQHC- Center.html. Services furnished must be within the practitioner’s state scope of practice.
Medicare-covered mental health services furnished incident to an RHC or FQHC visit are included in the payment for a medically necessary mental health visit when an RHC or FQHC practitioner furnishes a mental health visit. Group mental health services do not meet the criteria for a one-one-one, face-to-face encounter in an FQHC or RHC.
A mental health service should be reported using a valid HCPCS code for the service furnished, a mental health revenue code, and for FQHCs, an appropriate FQHC mental health payment code. For detailed information on reporting mental health services and claims processing, see Pub. 100-04, Medicare Claims Processing Manual, chapter 9, http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/clm104c09.pdf
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 9/12/24, pg. 42-43 (Accessed Mar. 2025).
Prior to March 27, 2020, RHCs and FQHCs were not authorized to serve as a distant site for telehealth consultations, which is the location of the practitioner at the time the telehealth service is furnished, and they could not bill or include the cost of a visit on the cost report. This included telehealth services that are furnished by an RHC or FQHC practitioner who is employed by or under contract with the RHC or FQHC, or a non-RHC or FQHC practitioner furnishing services through a direct or indirect contract. For more information on Medicare telehealth services, see Pub. 100-02, Medicare Benefit Policy Manual, chapter 15, and Pub. 100-04, Medicare Claims Processing Manual, chapter 12.
On March 27, 2020, Congress signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Section 3704 of the CARES Act authorized RHCs and FQHCs to provide distant site telehealth services to Medicare patients during the COVID-19 PHE. Section 4113 of the Consolidated Appropriations Act, 2023, extended this authority through December 31, 2024. Any health care practitioner working within their scope of practice can provide distant site telehealth services. Practitioners can provide distant site telehealth services – approved by Medicare as a distant site telehealth service under the physician fee schedule (PFS) – from any location in the United States (see 42 CFR 411.9(a)(1)), including their home, during the time that they’re employed by or under contract with the RHC or FQHC.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 9/12/24, pg. 46-47, (Accessed Mar. 2025).
RHCs and FQHCs may bill the Telehealth originating site facility fee on a RHC or FQHC claim under revenue code 0780 and HCPCS code Q3014. Telehealth services are the only services billed on FQHC claims that are subject to the Part B deductible. Additionally, a FQHC payment code and qualifying visit HCPCS code are not required when the only service reported on the claim is for Telehealth services. RHCs and FQHCs are not authorized to serve as distant practitioners for Telehealth services.
For more information on Telehealth services please see Pub 100-04, chapter 12, section 190: http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/clm104c12.pdf
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Claims Processing Manual Ch. 9, Update, Jun 7, 2023, pg. 36 (Accessed Mar. 2025).
A face-to-face encounter means an in-person or telehealth encounter between the treating practitioner and the beneficiary.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 5: Durable Medical Equipment, Prosthetics, Orthotics, Supplies (DMEPOS) Items and Services Having Special DME Review Considerations, 2/15/24, pg. 7, (Accessed Mar. 2025).
Q2: Are there any restrictions on the types of practitioners who can furnish Medicare telehealth services?
A2: Pursuant to the American Relief Act, 2025, through March 31, 2025, any practitioner who can independently bill Medicare for their professional services may furnish telehealth. This includes physical therapists, occupational therapists, speech-language pathologists, and audiologists.
Q4: How does CMS make payment for telehealth services furnished in RHCs and FQHCs? Can Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) continue to serve as distant sites for the provision of telehealth services?
A4: Any behavioral health service furnished by an RHC or FQHC on or after January 1, 2022 through interactive telecommunications technology is paid under the All Inclusive Rate (AIR) and Prospective Payment System (PPS), respectively. Through March 31, 2025, RHCs and FQHCs may continue to bill for non-behavioral health services furnished through interactive telecommunications technology by reporting HCPCS code G2025 on the claim.
Q5: Will in person visit requirements apply to behavioral health services furnished by professionals through Medicare telehealth? What about behavioral health services furnished remotely by hospital staff to beneficiaries in their homes, or behavioral health visits furnished by RHCs, and FQHCs where the patient is present virtually?
A5: The American Relief Act, 2025 has delayed in-person visit requirements for behavioral health services for professionals billing for Medicare telehealth services until April 1, 2025.
Regarding behavioral health services furnished remotely by hospital staff to beneficiaries in their homes, we are continuing to align our policy with requirements for Medicare telehealth services billed under the PFS. Accordingly, we are also delaying the in-person visit requirements for these services until April 1, 2025.
In the CY 2025 PFS final rule, we finalized that for behavioral health visits furnished by RHCs and FQHCs where the patient is present virtually, we are delaying in-person visit requirements until January 1, 2026.
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
Home Health (HH) Agencies
Starting on or after January 1, 2023, you may voluntarily report the use of telecommunications technology in providing HH services on HH payment claims. We’ll require this information on HH claims starting on July 1, 2023. You’ll submit the use of telecommunications technology on the HH claim using the following 3 G-codes:
- G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
- G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
- G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)
SOURCE: Telehealth Home Health Services: G-Codes, MLN Matters MM12805, (Effective Date: Jan. 1, 2023), (Accessed Mar. 2025).
Can MFTs and MHCs perform telehealth services?
Yes. MFTs and MHCs have been added to the list of practitioners who can furnish Medicare telehealth services.
During the COVID-19 public health emergency (PHE), CMS used emergency waiver and other regulatory authorities so you could provide more services to your patients via telehealth. Section 4113 of the CAA, 2023 extended many of these flexibilities through December 31, 2024, and made some of them permanent. For more information refer to Telehealth Services Fact Sheet.
SOURCE: Centers for Medicare and Medicaid Services, Marriage and Family Therapists and Mental Health Counselors, Provider Enrollment Frequently Asked Questions, May 2024, (Accessed Mar. 2025).
Opioid Treatment Programs
During the Public Health Emergency (PHE) for the COVID-19 pandemic, as well as after the conclusion of the PHE, therapy and counseling may be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology if two-way audio/video communications technology is not available to the beneficiary, provided all other applicable requirements are met, including circumstances in which the beneficiary is not capable of or does not consent to the use of devices that permit a two-way audio/video interaction
OTPs are allowed to furnish the substance use counseling, individual therapy, and group therapy included in the bundle via two-way interactive audio-video communication technology, as clinically appropriate, in order to increase access to care for beneficiaries. In addition, initiation of treatment with buprenorphine (but not methadone) via the OTP intake add-on code may be furnished via two-way audio-video communications technology to the extent that the use of audio-video telecommunications technology to initiate treatment with buprenorphine is authorized by DEA and SAMHSA at the time the service is furnished. For additional information please refer to Section 20 – Definitions relating to OTPs, C. Opioid use disorder treatment service. During the Public Health Emergency (PHE) for the COVID-19 pandemic, as well as after the conclusion of the PHE, therapy and counseling may be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology if two-way audio/video communications technology is not available to the beneficiary, provided all other applicable requirements are met, including circumstances in which the beneficiary is not capable of or does not consent to the use of devices that permit a two-way audio/video interaction.
Beginning January 1, 2021, OTPs are allowed to use two-way interactive audio-video communication technology, as clinically appropriate, to furnish the periodic assessment add-on code. Additionally, during the PHE which expired on May 11, 2023, in cases where a beneficiary did not have access to two-way audio-video communications technology, periodic assessments could be furnished using audio-only telephone calls if all other applicable requirements were met. Through the end of CY 2024, in cases where a beneficiary does not have access to two-way audio-video communications technology, periodic assessments can be furnished using audio-only telephone calls if all other applicable requirements are met.
Beginning January 1, 2023, OTPs are allowed to furnish the OTP intake add-on code via two-way audio- video communication technology when billed for the initiation of treatment with buprenorphine, to the extent that the use of audio-video telecommunications technology to initiate treatment with buprenorphine is authorized by DEA and SAMHSA at the time the service is furnished. OTPs are also allowed to use audio- only communication technology to initiate treatment with buprenorphine in cases where audio-video technology is not available to the beneficiary, including circumstances in which the beneficiary is not capable of or has not consented to the use of devices that permit a two-way, audio/video interaction.
OTPs providing intensive outpatient services to Medicare beneficiaries with an OUD shall not receive payment under Medicare part B if the intensive outpatient services are furnished via audio-video or audio-only communications technology.
Telemedicine services should not, under any circumstances, expand the scope of practice of a healthcare professional or permit practice in a jurisdiction (the location of the patient) where the provider is not licensed.
Counseling or therapy furnished via communication technology as part of OUD treatment services furnished by an OTP must not be separately billed by the practitioner furnishing the counseling or therapy because these services would already be paid through the bundled payment made to the OTP.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 17: Opioid Treatment Programs (OTPs), 12/21/23, (Accessed Mar. 2025).
Critical Access Hospitals
CMS will make reasonable cost-based reimbursement to the CAH for a telehealth service provided by a distant site physician or practitioner located at a CAH that is billing for that physician or practitioner’s professional services. Regardless of whether the CAH has or has not chosen the Optional Payment Method II for outpatient services, CMS will pay the CAH “101 percent of the reasonable costs for telehealth services when a physician or practitioners has reassigned their billing rights to the participating CAH and furnishes telehealth services from the participating CAH as a distant site practitioner.” This change also means that CAHs billing with the Standard Method on behalf of physician or practitioner employees are eligible to bill for telehealth delivered services provided by these employees as distant site providers. For those physicians and practitioners who have not reassigned their billing rights to the CAH, the payment will continue to be made under the Medicare physician fee schedule.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025 Rates, p. 1137-1138, (Accessed Mar. 2025).
CMS amended the Medicaid clinic services’ regulation to authorize Medicaid coverage for clinic services furnished by IHS/Tribal clinics outside the “four walls” of their facility. In addition, states implementing the Medicaid clinic services’ benefit can opt to cover clinic services furnished outside the “four walls” of behavioral health clinics or clinics located in rural areas. For clinics located in rural areas, based on comments received, CMS is finalizing an approach to defining “rural area” where states will select either a definition used by a federal agency for programmatic purposes, or a definition adopted by a state agency with a role in setting state rural health policy.
SOURCE: Center for Medicare and Medicaid Services, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems CY 2025 Rule, CMS-1809-FC, 11/27/24, (Accessed Mar. 2025).
ELIGIBLE SITES
Temporary Policy – Ends Sept. 30, 2025
In the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, with respect to telehealth services identified in subparagraph (F)(i) as of March 15, 2022, that are furnished during the period beginning on the first day after the end of such emergency period and ending on September 30, 2025, the term “originating site” means any site in the United States at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system, including the home of an individual.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) (Accessed Mar. 2025).
Permanent Policy
Eligible Sites:
- The office of a physician or practitioner.
- A critical access hospital
- A rural health clinic
- A Federally qualified health center
- A hospital
- A hospital-based or critical access hospital- based renal dialysis center (including satellites).
- A skilled nursing facility
- Rural emergency hospital
- A community mental health center
- A renal dialysis facility for purposes of individuals with end-stage renal disease getting home dialysis.
- The home of an individual, but only for purposes of individuals with end-stage renal disease getting home dialysis or telehealth services to treat substance use disorder or individuals with co-occurring mental health disorders, or mental health disorders under certain circumstances.
- Mobile Stroke Unit
- The home of an individual (only for purposes of treatment of a substance use disorder or a co-occurring mental health disorder, furnished on or after July 1, 2019, to an individual with a substance use disorder diagnosis.
- The home of a beneficiary for the purposes of diagnosis, evaluation, and/or treatment of a mental health disorder for services that are furnished during the period beginning on the first day after the end of the emergency period as defined in our regulation at § 400.200 and ending on December 31, 2024 except as otherwise provided in this paragraph. Payment will not be made for a telehealth service furnished under this paragraph unless the following conditions are met:
- The physician or practitioner has furnished an item or service in-person, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service;
- The physician or practitioner has furnished an item or service in-person, without the use of telehealth, at least once within 12 months of each subsequent telehealth service described in this paragraph, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens associated with an in-person service outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reason(s) for this decision in the patient’s medical record.
- The requirements of paragraphs (b)(3)(xiv)(A) and (B) may be met by another physician or practitioner of the same specialty and subspecialty in the same group as the physician or practitioner who furnishes the telehealth service, if the physician or practitioner who furnishes the telehealth service described under this paragraph is not available.
Note:
- The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act removed originating site geographic conditions and added an individual’s home as a permissible originating telehealth services substance use disorder or co-occurring mental health treatment site.
- Medicare doesn’t apply originating site geographic conditions to hospital-based and CAH based renal dialysis centers, renal dialysis facilities, and patient homes when practitioners provide monthly ESRD-related medical evaluations in patient homes. Independent Renal Dialysis Facilities aren’t eligible originating sites.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m) & 42 CFR Sec. 410.78. (Accessed Mar. 2025).
Requirements for mental health services furnished through telehealth (Delay of In-Person mental health requirement)
Payment may not be made under this paragraph for telehealth services furnished on or after October 1, 2025, by a physician or practitioner to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder unless such physician or practitioner furnishes an item or service in person, without the use of telehealth, for which payment is made under this subchapter (or would have been made under this subchapter if such individual were entitled to, or enrolled for, benefits under this subchapter at the time such item or service is furnished)—
- within the 6-month period prior to the first time such physician or practitioner furnishes such a telehealth service to the eligible telehealth individual; and
- during subsequent periods in which such physician or practitioner furnishes such telehealth services to the eligible telehealth individual, at such times as the Secretary determines appropriate.
This subparagraph shall not apply if payment would otherwise be allowed—
- under this paragraph (with respect to telehealth services furnished to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder); or
- under this subsection without application of this paragraph.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
Q8: Which place of service code should I use for telehealth services?
A8: Physicians and/or practitioners should use POS 02 for Telehealth Provided Other than in Patient’s Home or POS 10 for Telehealth Provided in Patient’s Home (which is a location other than a hospital or other facility where the patient receives care in a private residence). In the CY 2024 PFS final rule, we finalized that, starting January 1, 2024, claims for Medicare telehealth services provided to patients in their homes are to be paid at the non-facility payment rate.
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
An originating site is the location where a patient gets physician or practitioner medical services through telehealth. Before the COVID-19 PHE, patients needed to get telehealth at an originating site located in a certain geographic location.
Through March 31, 2025, COVID-19 PHE telehealth flexibilities allow patients to get telehealth wherever they’re located. They don’t need to be at an originating site, and there aren’t any geographic restrictions.
As of April 1, 2025:
- For non-behavioral or non-mental telehealth, there are originating site requirements and geographic location restrictions.
- For behavioral or mental telehealth, all patients can continue to get telehealth wherever they’re located, with no originating site requirements or geographic location restrictions. The patient’s home is a permissible originating site for services provided for diagnosing, evaluating, or treating:
- Mental health disorders
- Substance abuse disorder
- Monthly ESRD-related clinical assessments
Institutional Billing
Use modifier 95 when the clinician is in the hospital and the patient is in the home, as well as for outpatient therapy services provided via telehealth by qualified PTs, OTs, or SLPs employed by hospitals through December 31, 2024
Professional billing
Starting January 1, 2024, use:
- POS 02: Telehealth Provided Other than in Patient’s Home: The location where you provide health services and health-related services, through telecommunication technology. The patient isn’t located in their home when receiving health services or health-related services through telecommunication technology.
- POS 10: Telehealth Provided in Patient’s Home
- The location where you provide health services and health-related services through telecommunication technology. The patient is in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health-related services through telecommunication technology.
- As of January 1, 2024, we pay for telehealth services you provide to patients in their homes at the non-facility PFS rate. See MLN Matters® Article MM13452.
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Effective for claims with dates of service on and after January 1, 2024, claims for covered Telehealth services furnished at the distant site can be billed with POS code 10 when the patient is located in their home. Claims for covered Telehealth services using POS 10, if payable by Medicare, shall be paid at the Medicare Physician Fee Schedule non-facility rate.
The POS code 10 for Telehealth would not apply to originating site facilities billing a facility fee.
SOURCE: Centers for Medicare and Medicaid Services, Pub. 100-04, Medicare Claims Processing, Transmittal 12671, June 6, 2024, (Accessed Mar. 2025).
CMS clarified that services billed with POS 10 (telehealth provided in the patient’s home) will continue to be paid at the non-facility rate in 2025. CMS notes that while this policy was finalized in 2024, it was not limited to only being applicable to 2024.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
Q1: Do Medicare beneficiaries need to be located in a rural area and in a medical facility in order to receive Medicare telehealth services?
A1: Pursuant to the American Relief Act, 2025, beneficiaries can continue to receive Medicare telehealth services wherever in the United States and territories they’re located, including in their home, through March 31, 2025. They don’t need to be in a rural area or a medical facility
Q11: Are there geographic or place of service restrictions for behavioral health telehealth services (including SUD services)?
A11: No. The Consolidated Appropriations Act, 2021 permanently removed geographic and place of service restrictions for behavioral health telehealth services. Beneficiaries, including those in both rural and urban areas, can receive behavioral health telehealth services in their homes. Two-way, interactive, audio-only technology is permitted for behavioral health telehealth services.
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
The term originating site means the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs. For asynchronous, store and forward telecommunications technologies, an originating site is only a Federal telemedicine demonstration program conducted in Alaska or Hawaii.
Medicare beneficiaries are eligible for telehealth services only if they are presented from an originating site located in either a rural health professional shortage area (HPSA) as defined by §332(a)(1) (A) of the Public Health Services Act or in a county outside of an MSA as defined by §1886(d)(2)(D) (go to the link and select the applicable title) of the Act.
Effective January 1, 2014, rural HPSAs include HPSAs located outside of a county outside of an MSA as well as those located in rural census tracts as determined by the Office of Rural Health Policy. Also effective January 1, 2014, geographic eligibility for an originating site is established for each calendar year based upon the status of the area as of December 31st of the prior calendar year.
Exception to rural HPSA and non MSA geographic requirements Entities participating in a Federal telemedicine demonstration project that were approved by or were receiving funding from the Secretary of Health and Human Services as of December 31, 2000, qualify as originating sites regardless of geographic location. Such entities are not required to be in a rural HPSA or nonMSA.
The term originating site means the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs. Originating sites authorized by law are listed below:
- The office of a physician or practitioner;
- A hospital (inpatient or outpatient);
- A critical access hospital (CAH);
- A rural health clinic (RHC);
- A federally qualified health center (FQHC);
- A hospital-based or critical access hospital-based renal dialysis center (including satellites) (effective January 1, 2009);
- A skilled nursing facility (SNF) (effective January 1, 2009); and
- A community mental health center (CMHC) (effective January 1, 2009).
NOTE: Independent renal dialysis facilities are not eligible originating sites.
Payment for Telehealth for Individuals with Acute Stroke
Section 50325 of the Bipartisan Budget Act of 2018 amended section 1834(m) of the Act by adding a new paragraph (6) that provides special rules for telehealth services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke (acute stroke telehealth services), as determined by the Secretary. Specifically, section 1834(m)(6)(A) of the Act removes the restrictions on the geographic locations and the types of originating sites where acute stroke telehealth services can be furnished. Section 1834(m)(6)(B) of the Act specifies that acute stroke telehealth services can be furnished in any hospital, critical access hospital, mobile stroke units (as defined by the Secretary), or any other site determined appropriate by the Secretary, in addition to the current eligible telehealth originating sites. Section 1834(m)(6)(C) of the Act limits payment of an originating site facility fee to acute stroke telehealth services furnished in sites that meet the usual telehealth restrictions under section 1834(m)(4)(C) of the Act. These are identified in Section 190.1 of this chapter.
Effective for claims with dates of service on and after January 1, 2019, contractors shall accept new informational HCPCS modifier G0 (G zero), to be used to identify Telehealth services furnished for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke. Modifier G0 is valid for all:
- Telehealth distant site codes billed with Place of Service (POS) code 02 or Critical Access Hospitals, CAH method II (revenue codes 096X, 097X, or 098X); or
- Telehealth originating site facility fee, billed with HCPCS code Q3014
The term originating site means the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, (Accessed Mar. 2025).
The list of settings where a physician’s services are paid at the facility rate include: …
- Telehealth Provided Other than in Patient’s Home (POS code 02); …
Physicians’ services are paid at nonfacility rates for procedures furnished in the following settings:
- Telehealth Provided in Patient’s Home (POS code 10);
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 15-16, (Accessed Mar. 2025).
Exceptions to the in-person visit requirement require a clear justification documented in the patient’s medical record. Hospitals must also document that patients have a regular source of general medical care and can get any needed point-of-care testing, including vital sign monitoring and lab studies.
We created 3 Outpatient Prospective Payment System (OPPS)-specific HCPCS codes to describe that the patient must be in their home and that no associated professional service is billed under the PFS. Hospital staff must be licensed to provide these services consistent with all applicable state scope of practice laws. We exempt these services from having staff physically located in the hospital or outpatient department when providing services remotely using communication technology. See booklet for list of codes.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Learning Network Booklet 1986542, Medicare & Mental Health Coverage, Jul. 2024, (Accessed Mar. 2025).
CMS has directed place of service (POS) code 02 to be used for telehealth provided in places other than the patient’s home. POS code 10 should be used when telehealth is provided in the patient’s home.
SOURCE: Medicare Learning Network, MLN # MM12427, New/Modifications to the Place of Service POS Codes for Telehealth, Jan. 1, 2022 (implementation Apr. 4, 2022), (Accessed Mar. 2025).
In addition to the requirement for the in-person visit mentioned above in statute, CMS will also require there to be a an in-person, non-telehealth service within 12 months of each mental health telehealth service. However, if the patient and practitioner agree that the benefits of an in-person, non-telehealth service within 12 months of the mental health telehealth service are outweighed by risks and burdens associated with an in-person service, and the basis for that decision is documented in the patient’s medical record, the in-person visit requirement will not apply for that particular 12-month period. This applies only to patients receiving services at home. CMS will allow a clinician’s colleague in the same subspecialty in the same group to furnish the in-person, non-telehealth service to the beneficiary if the original practitioner is unavailable.
The home (for purposes of mental health reimbursement), can include temporary lodging, such as hotels and homeless shelters. CMS clarifies that for circumstances where the patient, for privacy or other personal reasons, chooses to travel a short distance from the exact home location during a telehealth services, the services is still considered to be furnished “in the home of an individual”.
In person requirement delayed under Medicare until on or after October 1, 2025.
SOURCE: CY 2022 Physician Fee Schedule, CMS, p. 63 & 64, (Accessed Mar. 2025).
Treatment of stroke telehealth services
The requirements described in paragraph (4)(C) shall not apply with respect to telehealth services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke, as determined by the Secretary.
With respect to telehealth services described in subparagraph (A), the term “originating site” shall include any hospital (as defined in section 1861(e)) or critical access hospital (as defined in section 1861(mm)(1)), any mobile stroke unit (as defined by the Secretary), or any other site determined appropriate by the Secretary, at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
After consideration of public comments, we are finalizing as proposed that beginning in CY 2024, claims for telehealth services billed with POS 10 will be paid at the non-facility PFS rate. Claims billed with POS 02 will continue to be paid at the facility rate. In addition, we are clarifying that modifier ’95’ should be used when the clinician is in the hospital and the patient is in the home, as well as for outpatient therapy services furnished via telehealth by PT, OT, or SLP.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
Accountable Care Organizations (two-sided model tested or expanded under 1115A of the Social Security Act)
In the case of telehealth services described in paragraph (1) where the home of a Medicare fee-for-service beneficiary is the originating site, the following shall apply:
- There shall be no facility fee paid to the originating site under section 1834(m)(2)(B).
- No payment may be made for such services that are inappropriate to furnish in the home setting such as services that are typically furnished in inpatient settings such as a hospital.
SOURCE: Social Security Act Sec. 1899 (Accessed Mar. 2025).
When physical and occupational therapists were allowed to provide services via telehealth, CMS used waiver authority to implement the Hospital Without Walls (HWW) policy that allowed the patients’ home to be classified as part of the hospital. This allowed the hospital “to bill both the hospital facility payment in association with professional services billed under the PFS and single payment for a limited number of practitioners services, when statute or other applicable rules only allow the hospital to bill for services personally provided by their staff. These services are either billed by hospitals or by professionals, there would not be separate facility and professional billing.” When the PHE ended, CMS originally thought to end this policy but is now considering whether some institutions may be able to bill for certain services provided remotely by employed practitioners. Therefore, institutional staff providing outpatient therapy, DSMT and MNT services via telehealth may bill the same way they did during the PHE until the end of 2024. For hospitals, beneficiaries’ homes will no longer need to be registered as provider-based departments of the hospital to allow for hospitals to bill for these services. With the exception of Method II critical access hospitals (CAHs), the 95 modifier will be used on each applicable line if telehealth is used. CAHs using Method II payment will continue using GT/GQ.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
- 02 Telehealth Provided Other than in Patient’s Home (January 1, 2017): The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
- 10 Telehealth Provided in Patient’s Home (January 1, 2022): The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
Beginning in CY 2024, practitioners may receive either the facility or the non-facility payment rate for an otherwise eligible Medicare telehealth service, depending on whether the billing practitioner selects POS code 02 or POS code 10. The only two valid POS codes for Medicare telehealth billing in CY 2024 are POS 02 and POS 10. As appropriate, POS 02 or POS 10 may be used and must be paired with the appropriate telehealth modifier (modifier 93 for audio-only and modifier 95 for audio/video). The payment rate for POS 02 is the facility payment rate (F); the payment rate for POS 10 is the non-facility rate (NF). Use of audio-only (93) or audio-video (95) does not change rate of payment, only the POS code determines the non-facility or facility payment rate.
Mobile Unit Setting
A physician or practitioner’s office, even if mobile, qualifies to serve as a telehealth originating site. Assuming such an office also fulfills the requirement that it be located in either a rural health professional shortage area as defined under section 332(a)(1)(A) of the Public Health Service Act (42 U.S.C. 254e(a)(1)(A)) or in a county that is not included in a Metropolitan Statistical Area as defined in section 1886(d)(2)(D) of the Act, the originating physician’s office should use POS code 11 (Office) in order to ensure appropriate payment for services on the list of Medicare Telehealth Services.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 26: Completing and Processing Form CMS-1500 Data Set, 8/9/24, pg. 23-32, (Accessed Mar. 2025).
Home Health Services
The face-to-face encounter can be performed via a telehealth service, in an approved originating site. An originating site is considered to be the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs. Medicare beneficiaries are eligible for telehealth services only if they are presented from an originating site located in a rural health professional shortage area or in a county outside of a Metropolitan Statistical Area.
Entities that participate in a Federal telemedicine demonstration project approved by (or receiving funding from) the Secretary of the Department of Health and Human Services as of December 31, 2000, qualify as originating sites regardless of geographic location.
The originating sites authorized by law are:
- The office of a physician or practitioner;
- Hospitals;
- Critical Access Hospitals (CAH);
- Rural Health Clinics (RHC);
- Federally Qualified Health Centers (FQHC);
- Hospital-based or CAH-based Renal Dialysis Centers (including satellites);
- Skilled Nursing Facilities (SNF); and
- Community Mental Health Centers (CMHC).
Section 1895(e) governs the home health prospective payment system (PPS) and provides that telehealth services are outside the scope of the Medicare home health benefit and home health PPS.
This provision does not provide coverage or payment for Medicare home health services provided via a telecommunications system. The law does not permit the substitution or use of a telecommunications system to provide any covered home health services paid under the home health PPS, or any covered home health service paid outside of the home health PPS. As stated in 42 CFR 409.48(c), a visit is an episode of personal contact with the beneficiary by staff of the home health agency (HHA), or others under arrangements with the HHA for the purposes of providing a covered service. The provision clarifies that there is nothing to preclude an HHA from adopting telemedicine or other technologies that they believe promote efficiencies, but there is no separate reimbursement for those technologies under the Medicare home health benefit. However, Medicare does recognize services furnished via telecommunications technology (see section 80.10) as an allowed administrative cost on Medicare cost reports if telecommunications technology is used by the HHA to augment the care planning process, and the technology is indicated on the plan of care.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 7: Home Health Services, 12/21/23, (Accessed Mar. 2025).
FQHCs/RHCs
RHCs and FQHCs may serve as an originating site for telehealth services, which is the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs. RHCs and FQHCs that serve as an originating site for telehealth services are paid an originating site facility fee.
Although FQHC services are not subject to the Medicare deductible, the deductible must be applied when an FQHC bills for the telehealth originating site facility fee, since this is not considered an FQHC service.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 9/12/24, pg. 46, (Accessed Mar. 2025).
CMS amended the Medicaid clinic services’ regulation to authorize Medicaid coverage for clinic services furnished by IHS/Tribal clinics outside the “four walls” of their facility. In addition, states implementing the Medicaid clinic services’ benefit can opt to cover clinic services furnished outside the “four walls” of behavioral health clinics or clinics located in rural areas. For clinics located in rural areas, based on comments received, CMS is finalizing an approach to defining “rural area” where states will select either a definition used by a federal agency for programmatic purposes, or a definition adopted by a state agency with a role in setting state rural health policy.
SOURCE: Center for Medicare and Medicaid Services, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems CY 2025 Rule, CMS-1809-FC, 11/27/24, (Accessed Mar. 2025).
GEOGRAPHIC LIMITS
Temporary Policy – Ends Dec. 31, 2024
In the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, with respect to telehealth services identified in subparagraph (F)(i) as of March 15, 2022, that are furnished during the period beginning on the first day after the end of such emergency period and ending on September 30, 2025, the term “originating site” means any site in the United States at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system, including the home of an individual.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
Permanent Policy
The term “originating site” means only those sites described below:
- In an area that is designated as a rural health professional shortage area under section 332(a)(1)(A) of the Public Health Service Act
- In a county that is not included in a Metropolitan Statistical Area; or
- From an entity that participates in a Federal telemedicine demonstration project that has been approved by (or receives funding from) the Secretary of Health and Human Services as of December 31, 2000.
The geographic requirements described in paragraph (4)(C)(i) shall not apply with respect to telehealth services furnished on or after January 1, 2019, for purposes of section 1395rr(b)(3)(B) of this title, at an originating site described in subclause (VI), (IX), or (X) of paragraph (4)(C)(ii).
The requirements described in paragraph (4)(C) shall not apply with respect to telehealth services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke, as determined by the Secretary.
With respect to telehealth services described in subparagraph (A), the term “originating site” shall include any hospital (as defined in section 1861(e)) or critical access hospital (as defined in section 1861(mm)(1)), any mobile stroke unit (as defined by the Secretary), or any other site determined appropriate by the Secretary, at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system.
Additional exceptions exist for treatment of substance use disorder and mental health (see below).
The Health Resources and Services Administration (HRSA) decides HPSAs and the Census Bureau decides MSAs. Find potential Medicare telehealth originating site payment eligibility at HRSA’s Medicare Telehealth Payment Eligibility Analyzer.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m), (Accessed Mar. 2025).
Medicare beneficiaries are eligible for telehealth services only if they are presented from an originating site located in either a rural health professional shortage area (HPSA) as defined by §332(a)(1) (A) of the Public Health Services Act or in a county outside of an MSA as defined by §1886(d)(2)(D) (go to the link and select the applicable title) of the Act.
Effective January 1, 2014, rural HPSAs include HPSAs located outside of a county outside of an MSA as well as those located in rural census tracts as determined by the Office of Rural Health Policy. Also effective January 1, 2014, geographic eligibility for an originating site is established for each calendar year based upon the status of the area as of December 31st of the prior calendar year.
Exception to rural HPSA and non MSA geographic requirements Entities participating in a Federal telemedicine demonstration project that were approved by or were receiving funding from the Secretary of Health and Human Services as of December 31, 2000, qualify as originating sites regardless of geographic location. Such entities are not required to be in a rural HPSA or nonMSA.
NOTE: Independent renal dialysis facilities are not eligible originating sites.
SOURCE: Center for Medicare and Medicaid Services, Medicare Claims Processing Manual, Chapter 12 – Physicians/Nonphysicians Practitioners (12/19/24), p. 167. (Accessed Mar. 2025).
An originating site is the location where a patient gets physician or practitioner medical services through telehealth. Before the COVID-19 PHE, patients needed to get telehealth at an originating site located in a certain geographic location.
Through March 31, 2025, COVID-19 PHE telehealth flexibilities allow patients to get telehealth wherever they’re located. They don’t need to be at an originating site, and there aren’t any geographic restrictions.
As of April 1, 2025:
- For non-behavioral or non-mental telehealth, there are originating site requirements and geographic location restrictions.
- For behavioral or mental telehealth, all patients can continue to get telehealth wherever they’re located, with no originating site requirements or geographic location restrictions. The patient’s home is a permissible originating site for services provided for diagnosing, evaluating, or treating:
- Mental health disorders
- Substance abuse disorder
- Monthly ESRD-related clinical assessments
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Except as provided in paragraph (b)(4)(iv) of this section, originating sites must be:
- Located in a health professional shortage area (as defined under section 332(a)(1)(A) of the Public Health Service Act (42 U.S.C. 254e(a)(1)(A)) that is either outside of a Metropolitan Statistical Area (MSA) as of December 31st of the preceding calendar year or within a rural census tract of an MSA as determined by the Office of Rural Health Policy of the Health Resources and Services Administration as of December 31st of the preceding calendar year, or
- Located in a county that is not included in a Metropolitan Statistical Area as defined in section 1886(d)(2)(D) of the Act as of December 31st of the preceding year, or
- An entity participating in a Federal telemedicine demonstration project that has been approved by, or receive funding from, the Secretary as of December 31, 2000, regardless of its geographic location.
The geographic requirements specified in paragraph (b)(4) of this section do not apply to the following telehealth services:
- Home dialysis monthly ESRD-related clinical assessment services furnished on or after January 1, 2019, at an originating site described in paragraphs (b)(3)(vi), (ix) or (x) of this section, in accordance with section 1881(b)(3)(B) of the Act; and
- Services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke.
- Services furnished on or after July 1, 2019 to an individual with a substance use disorder diagnosis, for purposes of treatment of a substance use disorder or a co-occurring mental health disorder.
- Services furnished on or after January 1, 2025 for the purposes of diagnosis, evaluation, and/or treatment of a mental health disorder. Payment will not be made for a telehealth service furnished under this paragraph unless the physician or practitioner has furnished an item or service in person, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service and within 6 months of any subsequent telehealth service.
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2025).
Accountable Care Organizations (two-sided model tested or expanded under 1115A of the Social Security Act)
In the case of telehealth services for which payment would otherwise be made under this title furnished on or after January 1, 2020, for purposes of this subsection only, the following shall apply with respect to such services furnished by a physician or practitioner participating in an applicable ACO (as defined in paragraph (2)) to a Medicare fee-for-service beneficiary assigned to the applicable ACO:
- Inclusion of home as originating site.—Subject to paragraph (3), the home of a beneficiary shall be treated as an originating site described in section 1834(m)(4)(C)(ii).
- No application of geographic limitation.—The geographic limitation under section 1834(m)(4)(C)(i) shall not apply with respect to an originating site described in section 1834(m)(4)(C)(ii) (including the home of a beneficiary under subparagraph (A)), subject to State licensing requirements.
SOURCE: Social Security Act Sec. 1899 (Accessed Mar. 2025).
Payment for Telehealth for Individuals with Acute Stroke
Section 50325 of the Bipartisan Budget Act of 2018 amended section 1834(m) of the Act by adding a new paragraph (6) that provides special rules for telehealth services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke (acute stroke telehealth services), as determined by the Secretary. Specifically, section 1834(m)(6)(A) of the Act removes the restrictions on the geographic locations and the types of originating sites where acute stroke telehealth services can be furnished. Section 1834(m)(6)(B) of the Act specifies that acute stroke telehealth services can be furnished in any hospital, critical access hospital, mobile stroke units (as defined by the Secretary), or any other site determined appropriate by the Secretary, in addition to the current eligible telehealth originating sites. Section 1834(m)(6)(C) of the Act limits payment of an originating site facility fee to acute stroke telehealth services furnished in sites that meet the usual telehealth restrictions under section 1834(m)(4)(C) of the Act. These are identified in Section 190.1 of this chapter.
Effective for claims with dates of service on and after January 1, 2019, contractors shall accept new informat HCPCS modifier G0 (G zero), to be used to identify Telehealth services furnished for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke. Modifier G0 is valid for all:
- Telehealth distant site codes billed with Place of Service (POS) code 02 or Critical Access Hospitals, CAH method II (revenue codes 096X, 097X, or 098X); or
- Telehealth originating site facility fee, billed with HCPCS code Q3014
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, (Accessed Mar. 2025).
Home Health Services
The face-to-face encounter can be performed via a telehealth service, in an approved originating site. An originating site is considered to be the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs. Medicare beneficiaries are eligible for telehealth services only if they are presented from an originating site located in a rural health professional shortage area or in a county outside of a Metropolitan Statistical Area.
Entities that participate in a Federal telemedicine demonstration project approved by (or receiving funding from) the Secretary of the Department of Health and Human Services as of December 31, 2000, qualify as originating sites regardless of geographic location.
The originating sites authorized by law are:
- The office of a physician or practitioner;
- Hospitals;
- Critical Access Hospitals (CAH);
- Rural Health Clinics (RHC);
- Federally Qualified Health Centers (FQHC);
- Hospital-based or CAH-based Renal Dialysis Centers (including satellites);
- Skilled Nursing Facilities (SNF); and
- Community Mental Health Centers (CMHC).
Section 1895(e) governs the home health prospective payment system (PPS) and provides that telehealth services are outside the scope of the Medicare home health benefit and home health PPS.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Benefit Policy Manual, Ch. 7: Home Health Services, 12/21/23, (Accessed Mar. 2025).
FACILITY/TRANSMISSION FEE
Eligible originating sites are eligible for a facility fee equal to:
- for the period beginning on October 1, 2001, and ending on December 31, 2001, and for 2002, $20; and
- for a subsequent year, the facility fee specified in subclause (I) or this subclause for the preceding year increased by the percentage increase in the MEI (as defined in section 1842(i)(3)) for such subsequent year.
Home: No facility fee shall be paid under this subparagraph to an originating site described in paragraph (4)(C)(ii)(X).
In the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, with respect to telehealth services identified in paragraph (4)(F)(i) as of March 15, 2022, that are furnished during the period beginning on the first day after the end of such emergency period and ending September 30, 2025, a facility fee shall only be paid under this subparagraph to an originating site that is described in paragraph (4)(C)(ii) (other than subclause (X) of such paragraph).
Treatment of Acute Stroke: No facility fee shall be paid under paragraph (2)(B) to an originating site with respect to a telehealth service described in subparagraph (A) if the originating site does not otherwise meet the requirements for an originating site under paragraph (4)(C).
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
The originating site facility fee is a separately billable Part B payment. The contractor pays it outside of other payment methodologies. This fee is subject to post payment verification.
For telehealth services furnished from October 1, 2001, through December 31, 2002, the originating site facility fee was the lesser of $20 or the actual charge. For services furnished on or after January 1 of each subsequent year, the originating site facility fee is updated by the Medicare Economic Index. The updated fee is included in the Medicare Physician Fee Schedule (MPFS) Final Rule, which is published by November 1 prior to the start of the calendar year for which it is effective. The updated fee for each calendar year is also issued annually in a Recurring Update Notification instruction for January of each year. See manual for more information about the payment amount and billing procedures for different types of entities.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 175-176, (Accessed Mar. 2025).
HCPCS Code Q3014 describes the Medicare telehealth originating sites facility fee. Bill your MAC for the separately billable Part B originating site facility fee. The payment amount for HCPCS code Q3014 (Telehealth originating site facility fee) is 80% of the lesser of the actual charge ($29.96 for CY 2024 services and $31.04 for CY 2025 services). We base this on the percentage increase in the Medicare Economic Index (MEI) as defined in section 1842(i)(3) of the Social Security Act. The 2025 MEI increase is 3.6%. The patient is responsible for any unmet deductible amount and coinsurance.
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Indian Health Services
All charges, except therapies, telehealth originating site facility fee, PPV, influenza virus and hepatitis B vaccines are combined and reported under revenue code 024X (all-inclusive ancillary) on TOB 12X (hospital inpatient Part B). Medicare Part B deductible and coinsurance amounts are applied to inpatient Medicare Part B ancillary services, but are waived by the IHS. The MSN is suppressed.
All charges, except for therapies, telehealth originating site facility fee, PPV, influenza virus vaccine, hepatitis B vaccine and hospital-based ambulance services are combined and reported under revenue code 0510 (clinic visit) on TOB 13X (hospital outpatient).
Effective January 1, 2009, IHS providers, including CAHs are paid separately from the AIR for the Telehealth Originating Site Facility Fee. HCPCS code Q3014 (“telehealth originating site facility fee”) is a Part B benefit. The fee is updated each calendar year by the Medicare Economic Index announced in the annual Physician Fee Schedule Final Regulation.
IHS providers are paid for HCPCS code Q3014 at the fee schedule payment, not the provider’s usual all-inclusive payment methodology (e.g., inpatient DRG or AIR or CAH per diem). For CAHs, the payment amount is 80 percent of the fee, not 101 percent of cost.
The Medicare Part B deductible and coinsurance apply to the Telehealth Originating Site Facility Fee, but are waived by the IHS.
The Telehealth Originating Site Facility Fee is reported on TOB 12X, 13X or 85X along with the revenue code 0780 and HCPCS code Q3014 as described in Chapter 12, Section 190 of Pub. 100-04, Medicare Claims Processing Manual.
No clinic visit shall be billed if this is the only service received. There is no requirement that a practitioner present the patient for interactive telehealth services.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 19: Indian Health Services, 5/20/22, pg. 36, 51-52, (Accessed Mar. 2025).
Federally Qualified Health Centers/Rural Health Clinics
RHCs and FQHCs may bill the Telehealth originating site facility fee on a RHC or FQHC claim under revenue code 0780 and HCPCS code Q3014. Telehealth services are the only services billed on FQHC claims that are subject to the Part B deductible. Additionally, a FQHC payment code and qualifying visit HCPCS code are not required when the only service reported on the claim is for Telehealth services. RHCs and FQHCs are not authorized to serve as distant practitioners for Telehealth services. For more information on Telehealth services please see Pub 100-04, chapter 12, section 190: http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/clm104c12.pdf
SOURCE: Center for Medicare and Medicaid Services, Medicare Claims Processing Manual, Chapter 9 – Rural Health Clinics/Federally Qualified Health Centers (Jun. 7, 2023), p. 36. (Accessed Mar. 2025).
Critical Access Hospitals
CMS will make reasonable cost-based reimbursement to Critical Access Hospitals (CAHs) serving as originating sites for a telehealth delivered service. The modified reimbursement rate for the facility fee to the CAH will be “101 percent of its reasonable costs for overhead, salaries and fringe benefits associated with the telehealth services at the participating CAH.”
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025 Rates, p. 1137-1138, (Accessed Mar. 2025).
Last updated 04/02/2025
Store and Forward
POLICY
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
Asynchronous store and forward technologies means the transmission of a patient’s medical information from an originating site to the physician or practitioner at the distant site. The physician or practitioner at the distant site can review the medical case without the patient being present. An asynchronous telecommunications system in single media format does not include telephone calls, images transmitted via facsimile machines and text messages without visualization of the patient (electronic mail). Photographs visualized by a telecommunications system must be specific to the patient’s medical condition and adequate for furnishing or confirming a diagnosis and or treatment plan. Dermatological photographs, for example, a photograph of a skin lesion, may be considered to meet the requirement of a single media format under this provision.
For Federal telemedicine demonstration programs conducted in Alaska or Hawaii only, Medicare payment is permitted for telehealth when asynchronous store and forward technologies, in single or multimedia formats, are used as a substitute for an interactive telecommunications system.
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2024).
For purposes of the preceding sentence, in the case of any Federal telemedicine demonstration program conducted in Alaska or Hawaii, the term “telecommunications system” includes store-and-forward technologies that provide for the asynchronous transmission of health care information in single or multimedia formats.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Mar. 2024).
Temporary Policy – Ends Dec. 31, 2024
The term “practitioner” has the meaning given that term in section 1395u(b)(18)(C) of this title and, in the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, for the period beginning on the first day after the end of such emergency period and ending on September 30, 2025, shall include a qualified occupational therapist (as such term is used in section 1395x(g) of this title), a qualified physical therapist (as such term is used in section 1395x(p) of this title), a qualified speech-language pathologist (as defined in section 1395x(ll)(4)(A) of this title), and a qualified audiologist (as defined in section 1395x(ll)(4)(B)).
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) (Accessed Mar. 2025).
Home Health (HH) Agencies
Starting on or after January 1, 2023, you may voluntarily report the use of telecommunications technology in providing HH services on HH payment claims. We’ll require this information on HH claims starting on July 1, 2023. You’ll submit the use of telecommunications technology on the HH claim using the following 3 G-codes:
- G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system …
- G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)
SOURCE: Telehealth Home Health Services: G-Codes, MLN Matters MM12805, (Effective Date: Jan. 1, 2023), (Accessed Mar. 2025).
CY 2024 Physician Fee Schedule notes that section 4113 of Division FF, Title IV, Subtitle A of the Consolidated Appropriations Act, 2023 (CAA, 2023) (Pub. L. 117-328, December 29, 2022) extends the telehealth policies enacted in the Consolidated Appropriations Act, 2022 (CAA, 2022) (Pub. L. 117-103, March 15, 2022) through December 31, 2024, if the PHE ends prior to that date, as discussed in section II.D.c. of this final rule. These provisions included:
- Temporarily removing the geographic and site requirements for the patient location at the time the telehealth interaction takes place
- Temporarily allowing a more expansive list of eligible providers in Medicare to provide services via telehealth such as physical and occupational therapists and federally qualified health centers (FQHCs) and rural health clinics (RHCs)
- Temporarily allowing some services to continue to be provided via audio-only
- Temporarily suspending the in-person service requirement prior to the delivery of mental and behavioral services via telehealth or audio-only in cases where the geographic requirement does not apply, the service takes place in the home and the patient was not being treated for a substance use disorder
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
For most non-behavioral or mental telehealth, you must use 2-way, interactive, audio-video technology.
For Alaska or Hawaii federal telemedicine demonstrations only, you may send medical information to a physician or practitioner by telehealth to review later.
Billing and Payment
- Bill covered telehealth to your Medicare Administrative Contractor (MAC). They pay you the appropriate telehealth amount under the Physician Fee Schedule (PFS).
- Submit professional telehealth claims using the appropriate CPT or HCPCS code.
- If you performed telehealth through asynchronous telehealth, add the telehealth GQ modifier with the professional service CPT or HCPCS code. You’re certifying you collected and sent the asynchronous medical file at the distant site from a federal telemedicine demonstration conducted in Alaska or Hawaii.
SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Jan. 2025, (Accessed Mar. 2025).
Q15: Why are non-face-to-face services (such as, but not limited to, Community Health Integration, Principal Illness Navigation, Chronic Care Management, Behavioral Health Integration, and Remote Monitoring) not on the Medicare Telehealth Services List?
A15: For these and similarly situated, non-face-to-face services, the telehealth restrictions are not applicable. Section 1834(m) of the Act limits payment for Medicare telehealth services to services that are in whole or in part, an inherently face-to-face service. Only services that serve as a substitute for an in-person encounter can be classified as a Medicare telehealth service. Services that do not require the presence of, or involve interaction with, the patient fall outside this definition. As discussed in prior rulemaking cycles, because these services do not serve as a substitute for an in-person encounter, we do not consider them to be Medicare telehealth services
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
Previously, the Balanced Budget Act of 1997 (BBA) limited the scope of Medicare telehealth coverage to consultation services and the implementing regulation prohibited the use of an asynchronous, ‘store and forward’ telecommunications system. BBA 1997 also required the professional fee to be shared between the referring and consulting practitioners, and prohibited Medicare payment for facility fees and line charges associated with the telemedicine encounter.
BIPA required that Medicare Part B (Supplementary Medical Insurance) pay for this expansion of telehealth services beginning with services furnished on October 1, 2001.
Section 149 of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) amended §1834 of the Act to add certain entities as originating sites for payment of telehealth services. Effective for services furnished on or after January 1, 2009, eligible originating sites include a hospital-based or critical access hospital-based renal dialysis center (including satellites); a skilled nursing facility (as defined in §1819(a) of the Act); and a community mental health center (as defined in §1861(ff)(3)(B) of the Act). MIPPA also amended§1888(e)(2)(A)(ii) of the Act to exclude telehealth services furnished under §1834(m)(4)(C)(ii)(VII) from the consolidated billing provisions of the skilled nursing facility prospective payment system (SNF PPS).
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 166, (Accessed Mar. 2025).
For purposes of this instruction, “store and forward” means the asynchronous transmission of medical information to be reviewed at a later time by physician or practitioner at the distant site. A patient’s medical information may include, but not limited to, video clips, still images, x-rays, MRIs, EKGs and EEGs, laboratory results, audio clips, and text. The physician or practitioner at the distant site reviews the case without the patient being present. Store and forward substitutes for an interactive encounter with the patient present; the patient is not present in real-time.
NOTE: Asynchronous telecommunications system in single media format does not include telephone calls, images transmitted via facsimile machines and text messages without visualization of the patient (electronic mail). Photographs must be specific to the patients’ condition and adequate for rendering or confirming a diagnosis and or treatment plan. Dermatological photographs, e.g., a photograph of a skin lesion, may be considered to meet the requirement of a single media format under this instruction
In the case of Federal telemedicine demonstration programs conducted in Alaska or Hawaii, store and forward technologies may be used as a substitute for an interactive telecommunications system. Covered store and forward telehealth services are billed with the “GQ” modifier, “via asynchronous telecommunications system.” By using the “GQ” modifier, the distant site physician/practitioner certifies that the asynchronous medical file was collected and transmitted to them at their distant site from a Federal telemedicine demonstration project conducted in Alaska or Hawaii.
If a contractor receives claims for professional telehealth services coded with the “GQ” modifier (representing “via asynchronous telecommunications system”), it shall approve/pay for these services only if the physician or practitioner is affiliated with a Federal telemedicine demonstration conducted in Alaska or Hawaii. The contractor may require the physician or practitioner at the distant site to document his or her participation in a Federal telemedicine demonstration program conducted in Alaska or Hawaii prior to paying for telehealth services provided via asynchronous, store and forward technologies.
Contractors shall deny telehealth services if the physician or practitioner is not eligible to bill for them.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 175, 181, (Accessed Apr. 2025).
ELIGIBLE SERVICES/SPECIALTIES
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
The term “telehealth service” means professional consultations, office visits, and office psychiatry services (identified as of July 1, 2000, by HCPCS codes 99241–99275, 99201–99215, 90804–90809, and 90862 (and as subsequently modified by the Secretary)), and any additional service specified by the Secretary.
The Secretary shall establish a process that provides, on an annual basis, for the addition or deletion of services (and HCPCS codes), as appropriate, to those specified in clause (i) for authorized payment under paragraph (1).
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Mar. 2025).
Medicare Part B pays for covered telehealth services included on the telehealth list when furnished by an interactive telecommunications system if the following conditions are met, except that for the duration of the Public Health Emergency as defined in § 400.200 of this chapter, Medicare Part B pays for office and other outpatient visits, professional consultation, psychiatric diagnostic interview examination, individual psychotherapy, pharmacologic management and end stage renal disease related services included in the monthly capitation payment furnished by an interactive telecommunications system if the following conditions are met.
Except as otherwise provided in this paragraph (f), changes to the list of Medicare telehealth services are made through the annual physician fee schedule rulemaking process. During the Public Health Emergency, as defined in § 400.200 of this chapter, we will use a subregulatory process to modify the services included on the Medicare telehealth list during the Public Health Emergency, taking into consideration infection control, patient safety, and other public health concerns resulting from the emergency. CMS maintains the list of services that are Medicare telehealth services under this section, including the current HCPCS codes that describe the services on the CMS website.
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2025).
List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth is available on the CMS website, including temporary codes during the public health emergency. Find the complete List of Telehealth Services by downloading the ZIP and opening the Excel or text files.
SOURCE: CMS Telehealth List Year 2025. (Accessed Mar. 2025).
Subject to paragraph (8), the Secretary shall pay to a physician or practitioner located at a distant site that furnishes a telehealth service to an eligible telehealth individual an amount equal to the amount that such physician or practitioner would have been paid under this subchapter had such service been furnished without the use of a telecommunications system.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Mar. 2025).
The physician or practitioner at the distant site must be licensed to furnish the service under State law. The physician or practitioner at the distant site who is licensed under State law to furnish a covered telehealth service described in this section may bill, and receive payment for, the service when it is delivered via a telecommunications system.
The practitioner at the distant site is one of the following:
- A physician
- A nurse practitioner
- Physician Assistant
- A clinical nurse specialist
- A nurse-midwife
- A clinical psychologist
- A clinical social worker
- A registered dietitian or nutrition professional
- A certified registered nurse anesthetist
- Any distant site practitioner who can appropriately bill for diabetes self-management training services may do so on behalf of others who personally furnish the services as part of the DSMT entity.
- A marriage and family therapist
- A mental health counselor
SOURCE: 42 CFR Sec. 410.78, (Accessed Mar. 2025).
After consideration of public comments, we are finalizing our proposal to add MFTs and MHCs as distant site practitioners for purposes of furnishing telehealth services. We are finalizing our proposed amendments to add MFTs and MHCs to the list of distant site practitioners in the telehealth regulation at § 410.78(b)(2)(xi),(xii).
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
After consideration of public comments, we are finalizing as proposed that beginning in CY 2024, claims for telehealth services billed with POS 10 will be paid at the non-facility PFS rate. Claims billed with POS 02 will continue to be paid at the facility rate. In addition, we are clarifying that modifier ’95’ should be used when the clinician is in the hospital and the patient is in the home, as well as for outpatient therapy services furnished via telehealth by PT, OT, or SLP.
Communication Technology-Based Services (CTBS)
CMS makes separate payment for remote evaluation of recorded video and/or images submitted by the patient. The code, G2010 describes remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with 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.
HCPCS code G2010 may be billed only for established patients. The follow-up with the patient could take place via phone call, audio/video communication, secure text messaging, email, or patient portal communication.
SOURCE CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Mar. 2025).
Online digital evaluation services (e-visit) are reimbursable for physicians and qualified non-physician health care professionals. These are non-face-to-face codes that describe patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office.
SOURCE CY 2020 Final Physician Fee Schedule. CMS, p. 799, (Accessed Mar. 2025).
Interprofessional consultations are reimbursable by CMS as part of their CTBS services (CPT codes include 99451, 99452, 99446, 99447, 99448, and 99449). Cost sharing will apply. These interprofessional services may be billed only by practitioners that can bill Medicare independently for evaluation and management services. Includes telephone and internet assessments.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Mar. 2025).
Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes these services to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.
RHCs and FQHCs may only bill for these services when the medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and does not lead to an RHC or FQHC service within the next 24 hours or at the soonest available appointment, since in those situations, Medicare already pays for the services as part of the RHC or FQHC per-visit payment.
RHCs and FQHCs can bill G0511, G0512, and G0071 alone or with other payable services on an RHC or FQHC claim.
SOURCE: Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, (Accessed Mar. 2025).
RHCs and FQHCs are not eligible for reimbursement of interprofessional consultation services, as only practitioners that can bill Medicare independently for evaluation and management services are eligible.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Mar. 2025).
New codes created that allow clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors to bill for interprofessional consultations with other practitioners whose practice is similarly limited, as well as with physicians and practitioners who can bill Medicare for E/M services and would use the current CPT codes to bill for interpersonal consultations. These new G codes for behavioral health services were finalized: G0546-G0551. Patient consent must be obtained in advance of the services.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Mar. 2025).
Also see Table 11 for list of eligible codes in CY 2024 Physician Fee Schedule.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Mar. 2025).
GEOGRAPHIC LIMITS
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
For asynchronous store and forward telecommunications technologies, the only originating sites are Federal telemedicine demonstration programs conducted in Alaska or Hawaii.
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2025).
Temporary Policy – Ends Dec. 31, 2024
In the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, with respect to telehealth services identified in subparagraph (F)(i) as of March 15, 2022, that are furnished during the period beginning on the first day after the end of such emergency period and ending on September 30, 2025, the term “originating site” means any site in the United States at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system, including the home of an individual.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m) (Accessed Mar. 2025).
Permanent Policy
Except as provided in clause (iii) and paragraphs (5), (6), and (7), the term “originating site” means only those sites described in clause (ii) at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system and only if such site is located—
- in an area that is designated as a rural health professional shortage area under section 254e(a)(1)(A) of this title;
- in a county that is not included in a Metropolitan Statistical Area; or
- from an entity that participates in a Federal telemedicine demonstration project that has been approved by (or receives funding from) the Secretary of Health and Human Services as of December 31, 2000.
The geographic requirements described in paragraph (4)(C)(i) shall not apply with respect to telehealth services furnished on or after January 1, 2019, for purposes of section 1395rr(b)(3)(B) of this title, at an originating site described in subclause (VI), (IX), or (X) of paragraph (4)(C)(ii).
Additional exceptions exist for treatment of acute stroke and substance use disorder (see below).
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Mar. 2025).
For asynchronous, store and forward telecommunications technologies, an originating site is only a Federal telemedicine demonstration program conducted in Alaska or Hawaii.
In the case of Federal telemedicine demonstration programs conducted in Alaska or Hawaii, Medicare payment is permitted for telemedicine when asynchronous “store and forward technology” in single or multimedia formats is used as a substitute for an interactive telecommunications system. The originating site and distant site practitioner must be included within the definition of the demonstration program.
For asynchronous, store and forward telecommunications technologies, an originating site is only a Federal telemedicine demonstration program conducted in Alaska or Hawaii.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Claims Processing Manual, Ch. 12 – Physicians/Nonphysician Practitioners, Revised 12/19/24, pg. 168, 174, (Accessed Mar. 2025).
Eligible Sites:
- The office of a physician or practitioner.
- A critical access hospital
- A rural health clinic
- A Federally qualified health center
- A hospital
- A hospital-based or critical access hospital-based renal dialysis center (including satellites).
- A skilled nursing facility
- Rural emergency hospital
- A community mental health center
- A renal dialysis facility for purposes of individuals with end-stage renal disease getting home dialysis.
- The home of an individual, but only for purposes of individuals with end-stage renal disease getting home dialysis or telehealth services to treat substance use disorder or individuals with co-occurring mental health disorders, or mental health disorders under certain circumstances.
- Mobile Stroke Unit
- The home of a beneficiary for the purposes of diagnosis, evaluation, and/or treatment of a mental health disorder for services furnished on or after the first day after the end of the PHE as defined in our regulation at § 400.200 except as otherwise provided in this paragraph. Payment will not be made for a telehealth service furnished under this paragraph unless the following conditions are met:
- The physician or practitioner has furnished an item or service in-person, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service;
- The physician or practitioner has furnished an item or service in-person, without the use of telehealth, at least once within 12 months of each subsequent telehealth service described in this paragraph, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens associated with an in-person service outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reason(s) for this decision in the patient’s medical record.
- The requirements of paragraphs (b)(3)(xiv)(A) and (B) may be met by another physician or practitioner of the same specialty and subspecialty in the same group as the physician or practitioner who furnishes the telehealth service, if the physician or practitioner who furnishes the telehealth service described under this paragraph is not available.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m) & 42 CFR Sec. 410.78. (Accessed Mar. 2025).
Substance Use Disorder
The geographic requirements described in paragraph (4)(C)(i) shall not apply with respect to telehealth services furnished on or after July 1, 2019, to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder, as determined by the Secretary, or, on or after the first day after the end of the emergency period described in section 1320b–5(g)(1)(B) of this title, subject to subparagraph (B), to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder, as determined by the Secretary, at an originating site described in paragraph (4)(C)(ii) (other than an originating site described in subclause (IX) of such paragraph) or, for the period for which clause (iii) of paragraph (4)(C) applies, at any site described in such clause.
Requirements for mental health services furnished through telehealth
Payment may not be made under this paragraph for telehealth services furnished on or after October 1, 2025, by a physician or practitioner to an eligible telehealth individual for purposes of diagnosis, evaluation, or treatment of a mental health disorder unless such physician or practitioner furnishes an item or service in person, without the use of telehealth, for which payment is made under this subchapter (or would have been made under this subchapter if such individual were entitled to, or enrolled for, benefits under this subchapter at the time such item or service is furnished)—
- within the 6-month period prior to the first time such physician or practitioner furnishes such a telehealth service to the eligible telehealth individual; and
- during subsequent periods in which such physician or practitioner furnishes such telehealth services to the eligible telehealth individual, at such times as the Secretary determines appropriate.
These requirements do not apply to services:
- under this paragraph (with respect to telehealth services furnished to an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder); or
- Under this subsection without application of this paragraph.
[Implementation delayed until Jan. 1, 2025]
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Mar. 2025).
Originating sites must be:
- Located in a health professional shortage area (as defined under section 332(a)(1)(A) of the Public Health Service Act (42 U.S.C. 254e(a)(1)(A)) that is either outside of a Metropolitan Statistical Area (MSA) as of December 31st of the preceding calendar year or within a rural census tract of an MSA as determined by the Office of Rural Health Policy of the Health Resources and Services Administration as of December 31st of the preceding calendar year, or
- Located in a county that is not included in a Metropolitan Statistical Area as defined in section 1886(d)(2)(D) of the Act as of December 31st of the preceding year, or
- An entity participating in a Federal telemedicine demonstration project that has been approved by, or receive funding from, the Secretary as of December 31, 2000, regardless of its geographic location.
The geographic requirements specified above do not apply to the following telehealth services:
- Home dialysis monthly ESRD-related clinical assessment services furnished on or after January 1, 2019, at an originating site described in paragraphs (b)(3)(vi), (ix) or (x) of this section, in accordance with section 1881(b)(3)(B) of the Act; and
- Services furnished on or after January 1, 2019, for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke.
- Services furnished on or after July 1, 2019 to an individual with a substance use disorder diagnosis, for purposes of treatment of a substance use disorder or a co-occurring mental health disorder.
- Services furnished on or after January 1, 2025 for the purposes of diagnosis, evaluation, and/or treatment of a mental health disorder. Payment will not be made for a telehealth service furnished under this paragraph unless the physician or practitioner has furnished an item or service in person, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service and within 6 months of any subsequent telehealth service.
SOURCE: 42 CFR Sec. 410.78 (Accessed Mar. 2025).
Communication Technology-Based Services (CTBS)
Geographic limits do not apply to Communication Technology-Based Services.
TRANSMISSION FEE
Store and Forward For Telehealth Demonstration Projects in Alaska and Hawaii Only:
Subject to clauses (ii) and (iii) and paragraph (6)(C), with respect to a telehealth service, subject to section 1395l(a)(1)(U) of this title, there shall be paid to the originating site a facility fee equal to—
- for the period beginning on October 1, 2001, and ending on December 31, 2001, and for 2002, $20; and
- for a subsequent year, the facility fee specified in subclause (I) or this subclause for the preceding year increased by the percentage increase in the MEI (as defined in section 1395u(i)(3) of this title) for such subsequent year.
Home: No facility fee shall be paid under this subparagraph to an originating site described in paragraph (4)(C)(ii)(X).
New Sites: In the case that the emergency period described in section 1320b–5(g)(1)(B) of this title ends before December 31, 2024, with respect to telehealth services identified in paragraph (4)(F)(i) as of March 15, 2022, that are furnished during the period beginning on the first day after the end of such emergency period and ending September 30, 2025, a facility fee shall only be paid under this subparagraph to an originating site that is described in paragraph (4)(C)(ii) (other than subclause (X) of such paragraph).
Treatment of Acute Stroke: No facility fee shall be paid under paragraph (2)(B) to an originating site with respect to a telehealth service described in subparagraph (A) if the originating site does not otherwise meet the requirements for an originating site under paragraph (4)(C).
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Mar. 2025).
Communication Technology-Based Services (CTBS)
No originating site fee (Q3014) reimbursed for Communication Technology-Based Services.
