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 Jul. 2024).
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 Jul. 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 December 31, 2024, 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 Jul. 2024).
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 (Do you need this bit here since it’s the asynch section?)
- 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 Jul. 2024).
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 Jul. 2024).
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, Apr. 2024, (Accessed Jul. 2024).
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 6/6/24, pg. 141-142, (Accessed Jul. 2024).
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 6/6/24, pg. 145, (Accessed Jul. 2024).
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.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Jul. 2024).
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 Jul. 2024).
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 2023, Updated 11/13/23. (Accessed Jul. 2024).
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 title had such service been furnished without the use of a telecommunications system.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 Jul. 2024).
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 December 31, 2024, 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 Jul. 2024).
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 shall not apply with respect to telehealth services furnished on or after January 1, 2019, for purposes of the home dialysis monthly ESRD-related visit, at a hospital-based or critical access hospital-based renal dialysis center, a renal dialysis facility, or the home.
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 Jul. 2024).
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 6/6/24, pg. 145, (Accessed Jul. 2024).
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 Jul. 2024).
Substance Use Disorder
The geographic requirements 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 1135(g)(1)(B), 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 any originating site except a renal dialysis facility.
Requirements for mental health services furnished through telehealth
Payment may not be made under this paragraph for telehealth services furnished 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 title:
- 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 Jul. 2024).
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 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 Jul. 2024).
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:
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.
No facility fee shall be paid under this subparagraph to an originating site that is the home.
Treatment of Acute Stroke: No facility fee shall be paid to an originating site with respect to a telehealth service if the originating site does not otherwise meet the requirements for an originating site, including geographic requirements.
SOURCE: Social Security Act, Sec. 1834(m) (US Code Title 42, Sec. 1395m). (Accessed Jul. 2024).
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 Jul. 2024).
Communication Technology-Based Services (CTBS)
No originating site fee (Q3014) reimbursed for Communication Technology-Based Services.
READ LESS