COVID-19 Telehealth Reimbursement Update

Telehealth reimbursement

COVID-19 Telehealth Reimbursement Update*

Telehealth reimbursement for services delivered during COVID-19 has reportedly been variable. Practitioners across professions are voicing complaints about rejected billing. In this brief article, the Telebehavioral Health Institute (TBHI) summarizes current events as reported from key associations and news outlets to help you better understand to be successful at telehealth reimbursement. This article also points to resources and concludes by inviting the TBHI community to weigh in with their experiences to help shed some light on practical solutions.

Update to COVID-19 Telehealth Reimbursement 

On 3/31/2020, CMS changed regulations for the use of telehealth in the Medicare program, including the use of telephone, and licensure for Medicare providers. Those changes have repercussions for both Medicare and commercial payers. Both systems will be addressed below, along with resources for professionals wishing to learn more. Since then, a number of groups have been posting updates to their COVID-19 reimbursement information.

Background: On March 17, 2020, the Center for Medicare and Medicaid Services Administration (CMS) released guidance allowing patients to be seen via live, 2-way interactive videoconferencing in their homes. This change is a marked deviation from previous telehealth rules, which only allowed telehealth visits to be received by clients and patients who were required to travel to a qualifying “originating site” for telehealth encounters reimbursed by Medicare. Reimbursement was only available to clinicians in specific professions, which in the behavioral community, in effect, excluded counselors, Couples and marriage therapists (MFTs), addiction professionals, and behavior analysts.

The article below is a summary of information found across guidance in the behavioral and medical professions. Key links are provided for your convenience.

Current COVID-19 Telehealth Reimbursement

Many private payers may ask for a billing standard that is similar to Medicare, including the use of the same modifier and Place of Service (POS) codes. Click here to read the release from the Center for Medicare and Medicaid Services (CMS), which provides detailed Fact Sheets and FAQs defining a telehealth encounter for reimbursement purposes. Summarizes are provided for you below.

    • On the 1500 claim form, use the same CPT codes as would be used for an in-person encounter.
    • Use the modifier “95” after each CPT code to indicate the care was provided through telehealth.
    • In conducting a telehealth encounter, professionals are to use the same CPT codes on the 1500 form as if the encounter were in-person.
    • Use the “11” Place of Service (POS) that aligns with the specific encounter, just as they would when seeing clients and patients in person.  
    • The American Psychological Association published an article summarizing telehealth reimbursement and giving using 1500 forms for two Medicare case examples. See Billing for psychological services provided during the COVID-19 public health emergency
    • The American Psychiatric Association has developed a list of responses by individual commercial payors, which can be found at the bottom of this page: Telepsychiatry and COVID-19  They have also provided a model letter for providers to use when contacting these payors. 

CPT Codes Allowed for Telephone-Only or Traditional Telehealth

  • Payments for telephone (audio) only services are retroactive to 3/1/2020.
    • Diagnostic Interview (90791, 90792)
    • Psychotherapy (90832, 90833, 90834, 90836, 90837, 90838)
    • Psychoanalysis (90845)
    • Group Psychotherapy (90853)
    • Family Psychotherapy (90846, 90847)
    • Crisis Intervention and Interactive Complexity (90839, 90840, 90785)
    • Neurobehavioral Status Exam (96116, 96121)
    • Psychological Evaluation (96130, 96131)
    • Neuropsychological Evaluation (96132, 96133)
    • Psychological and Neuropsychological Test Administration and Scoring (96136, 96137, 96138, 96139)
    • Health Behavior Assessment (96156)
    • Health Behavior Intervention, Individual (96158, 96159)
    • Health Behavior Intervention, Group (96164, 96165)
    • Health Behavior Intervention, Family with the patient (96167, 96178)
    • Behavioral Screening (96127)
    • CMS also announced they will be increasing payments for audio-only telephone visits (99441, 99442, 99443) between Medicare beneficiaries and their providers to match payments for similar office and outpatient visits.
    • Screening, Brief Intervention, and Referral to Treatment (G0396, G0397)
  • See American Psychological Association article: Phone only telehealth services for Medicare during COVID-19

Forensic and Other Assessment Specialists

The American Psychological Association issued guidance for assessment professionals that includes reimbursement in a number of articles:

COVID-19 Telehealth Reimbursement for Medicare

  • For telehealth, use the same CPT codes as if the encounter were in-person, but with these factors considered: 
    • For new telepsychiatry encounters provided to patients under the waiver that would have been office visits, psychiatrists should consider their office as the place of service (POS) and use the place of service code 11, just as you did when you were seeing your patients in person. If you are providing inpatient care, you should use the place of service you would ordinarily use for that place even though you are not actually there. You should use the same CPT codes you would use for an in-person encounter, and on the 1500 Claim Form you should add the modifier 95 after each CPT code to indicate the care was provided as telemedicine. These same directions should be applicable for most commercial payers as well. Please let APA know if your experience is different.
    • Those psychiatrists who were previously providing telepsychiatry under Medicare’s pre-waiver rules should continue to report this care as they always have, for example, with POS 02.
    • For more information on telepsychiatry during COVID, see our Telepsychiatry blog.
  • CMS guidance dated March 17, 2020, allows patients to be seen via live videoconferencing in their homes.
  • The Office of Civil Rights (OCR) has indicated they will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through a variety of technologies, but providers must use as many safety precautions as possible, and clients and patients must be informed of potential risks. Examples of currently allowed technology that is otherwise non-HIPAA compliant are FaceTime or Skype. When possible, however, clinicians are encouraged to protect their clients and patients by using HIPAA-compliant services. (See TBHI Buyer’s Guide for options.)
  • While Medicare coinsurance and deductibles would normally apply to these services, but HHS Office of Inspector General (OIG) is allowing professionals to waive these payments. Of note is that these payments typically are collected by the provider. The OIG then, in essence, is allowing the provider to waive co-pays.
  • Announced on 5-11-2020, CMS updated a video that answers common questions about the expanded Medicare telehealth services benefit during the COVID-19 public health emergency. New information includes how CMS adds services to the list of telehealth services, additional practitioners that can provide telehealth services, and the distant site services that Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) can provide.

CMS Gives States Additional Flexibility to Address Coronavirus Pandemic – UPDATE 5-11-2020

CMS has approved over 175 requests for state relief in response to the COVID-19 pandemic, including recent approvals for Alabama, Alaska, California, District of Columbia, Georgia, Maine, Massachusetts, Minnesota, Mississippi, Montana, Nebraska, New Mexico, Oregon, South Carolina, Rhode Island, Tennessee, Virginia, and Wisconsin. These approvals help to ensure that states have the tools they need to combat COVID-19 through a wide variety of waivers, amendments, and Medicaid state plan flexibilities, including support for programs that care for the elderly and people with disabilities.

CMS Toolkit

CMS has developed a toolkit to expedite the application and review of each request and has approved these requests in record time. 

Section 1135 Waivers

Section 1115(a) Waivers 

1915(c) Waiver Appendix K Amendments

Medicaid State Plan Amendments

CHIP State Plan Amendments

Ryan Haight Act

The Ryan Haight Act requires an initial, in-person assessment of a patient to establish a professional relationship prior to digitally prescribing a controlled substance. As of March 17, 2020, the DEA has suspended this requirement.

Inpatient Psychiatric Settings (ECT)

In response to the March 18 announcement by the Centers for Medicare & Medicaid Services (CMS) recommendations regarding adult elective surgeries, and non-essential medical, surgical, and dental procedures during the COVID-19 outbreak, the American Psychiatric Association has taken the position that ECT an essential procedure. For more information, see their statement here: Telepsychiatry and COVID-19 

COVID-19 Telehealth Reimbursement: Substance Use Disorders (SUDs)

COVID-19 Telehealth Reimbursement: State-Based Guidance

A variety of sources have published guidance for providers interested in following developments at their state level.

COVID-19 Telehealth Reimbursement: E-Visits

An e-Visit is a patient-initiated communication using digital patient portals, which are websites that give patients 24-hour access to personal health information. The patient logs into a secured area from anywhere with an Internet connection, using a secure username and password. Portals can include communication technology for established patients to use to send secure messages to the provider or their staff. These digital assessment services allow the provider to make clinical decisions that otherwise would have been provided in the office. CPT codes are available to bill for such services, however, Medicare co-insurance and deductible amounts cannot be waived for such visits.

During COVID, CMS is not enforcing the requirement limiting E-Visits to established patients only. 
The service description for non-medical professionals to use when billing is: “Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days.”

  • G2061: cumulative time of 5-10 minutes during the seven days 
  • G2062: cumulative time of 11-20 minutes during the seven days 
  • G2063: cumulative time of 21 or more minutes during the seven days

Getting Rejection Notices?COVID-19 Telehealth Reimbursement Other Resources

  • The American Professional Agency, Inc, a malpractice carrier that has been supportive of telehealth for over a decade, has developed these COVID-19 resources:
  • If you are having difficulty getting paid by any payor, including the commercial payors, consider taking these steps:
    • Contact your state Insurance Commissioner. They are empowered to intervene on your behalf with insurance companies who are ignoring the law. You can find email addresses for your state legislators and Insurance Commissioners by going to your state websites.
    • Write a letter to your members of Congress
    • If you are not getting paid by Medicare, send a letter to CMS Administrator Seema Verma and HHS Secretary Alex Azar at the addresses below:

The Honorable Seema Verma

Secretary Administrator

U.S. Department of Health & Human Services Centers for Medicare & Medicaid Services

200 Independence Avenue, S.W. 200 Independence Avenue, S.W.

Washington, D.C. 20201 Washington, D.C. 20201


The Honorable Alex Azar

SecretaryU.S. Department of Health & Human Services 

200 Independence Avenue, S.W.

Washington, D.C. 20201

Further TBHI Reading

TBHI Training

Telehealth Reimbursement Strategies: Increasing Authorization & Payment 


To the best of its ability, TBHI offers you news, educational information and points you to key resources. It does not and cannot offer you legal or financial advice for your specific practice. In this time of rapid change, many policies are in flux. You should regularly check with links provided as well as directly with payors to confirm their billing, coding and reimbursement policies, which can vary widely across programs, states and payors. You may also want to note that some payors are reportedly operating in violation of the law, in which case, you may want to contact the agencies listed above and seek direction from a qualified attorney in your jurisdiction.

What is Your COVID-19 Telehealth Reimbursement Experience?

Please take a few minutes to post your recent experiences and insights in the comment section below for the TBHI community. Additional useful resources are also invited. If you know if a key document that might help the community with telehealth reimbursement, please post below. We’re all this together.

Your TBHI Professional Training Options

TBHI specializes in teaching you how to relax when delivering telehealth.  It offers you a step-by-step learning path of online training that helps you be legally and ethically compliant, clinically proficient, and able to handle even the most difficult of clinical scenarios. Take advantage of COVID discount pricing to learn how to sit back and enjoy your telehealth experiences, rather than struggling with ZOOM fatigue and clinical uncertainty. All courses are evidence-based, available 24/7 through any device and most count toward legal and ethical requirements for licensure. Two micro certifications are also available.

    1. Telehealth Group Therapy  — Exciting, highly interactive telehealth learning experience designed to get answers to your questions about legally and ethically managing telehealth group therapy. Digital class will allow you to connect with colleagues ahead of time to ask questions and share answers. Distinguished faculty will lead you through telehealth group therapy theory and exercises.
    2. Telehealth Clinical Best Practices Workshop — Live, interactive webinar, w/ 4 CME or CE hours to discuss preventing and handling complex clinical issues.
    3. Course Catalog
    4. Micro Certifications to give you a broader range of legal and ethical grounding, and allow you to distinguish yourself as a TBHI-credentialed professional on your websites, in social media, directories and other areas.

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2 comments on “COVID-19 Telehealth Reimbursement Update

  1. Excluding early snaggs in cohesive directions across providers, claims processing and Medicare provider relations, we have not experienced problems with CMS claims payment. The problem is with BWC. BWC mandates psychotherapy delivered via telephone only be billed as 99373 with a rate $134.57 less than the fee schedule for face to face therapy.
    Same service, same amount of time with patient = $134.57 less due to means of delivery. It’s simply not right.

    • Marie, Thank you for the update. I appreciate your taking the time to let others in our community know your experience.

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