Virtual Services Billing Guidelines

If your practice is exploring alternative methods to remotely check-in with your patients and evaluate their health, there are a number of telemedicine services that may be reimbursable by CMS and private payers, or services you may decide to fold into your membership or cash-based offerings. CMS specifically categorizes virtual services into 4 groups: telehealth visits, virtual check-ins, eVisits and (new) telephone-only E/M.

See the table below for billable codes associated with each of these telemedicine services. As coding requirements may differ by payer, we recommend confirming requirements before you submit your claims.

	Telehealth	Virtual Check-ins	Telephone E/M	eVisits
Communication Mechanism	2-way interactive audio-visual Note: Some states are allowing audio only*	Phone call or Image/video sent by patient and reviewed async by provider	Phone call	HIPAA compliant patient portal/secure messaging system
Medicare FFS Billing	CPT Codes – 99201-99205 – 99211-99215 – G0438-G0439 (AWV) For Facility Rate: – POS 2 – Generally no modifier, unless GQ for Alaska/Hawaii federal demonstration program For Non-Facility Rate: Generally higher reimbursement – POS 11 – Modifier 95	Phone: – G2012 Image/video: – G2010	Qualified Non-Physician: – 98966-98968 Physician: – 99441-99443	Qualified Non-Physician: – G2061-G2063 Physician: – 99421-99423

For additional information on billing and workflow recommendations for virtual services, please visit this link.

If you are seeing non-member patients, we recommend taking the following steps:

1. Create a rate for Telehealth visits. Most practices will apply their general face-to-face visit fees, matching a similar payment pattern seen in the fee-for-service model.
2. Create a mechanism to track these patients to distinguish them from membership patients. If you are Hint-integrated, use a patient tag to track “non-Members” in Hint. If you are not Hint-integrated, use a patient tag to track “non-Members” in Elation