Updated Nov. 5, 2021
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The policy and payment landscape around telehealth and telemedicine remains complex; however, as the country navigates this pandemic, change is happening rapidly to expand these services. The AMA’s Advocacy team has been summarizing the latest updates in Federal policy.
Here are some additional key policy and payment considerations to keep in mind:
- Ensure that you are providing services in accordance with your state laws and regulations. As part of emergency declarations, many governors have relaxed state laws and regulations related to the provision of telehealth services. For up to the minute information in your state, please contact your state department of health or state medical association.
- If you are licensed in the state where the patient is located, there are no additional requirements.
- If you are not licensed in the state where the patient is located:
- CMS has issued the following waiver for Medicare patients: Temporarily waive requirements that out-of-state providers be licensed in the state where they are providing services when they are licensed in another state. Physicians are still bound by their state licensing requirements (CMS FAQs). Medicaid waivers must be requested by the individual state that wants to use them.
- Many states have temporarily relaxed licensure requirements related to physicians licensed in another state and retired or clinically inactive physicians. This includes waiving licensure requirements or offering a temporary expedited license for out-of-state physicians. Many, but not all of these measures apply to physicians providing telemedicine across state lines. Please contact your state board of medicine or department of health for up-to-the minute information.
- The Federation of State Medical Boards (FSMB) is tracking executive orders related to licensure. Stay up to date on the FSMB website.
- CMS has expanded access to telemedicine services for all Medicare beneficiaries, not just those that have novel coronavirus, for the duration of the COVID-19 Public Health Emergency. In addition to existing coverage for originating sites including physician offices, skilled nursing facilities and hospitals, Medicare will now make payments for telehealth services furnished in any healthcare facility and in the home.
Common CPT codes for telemedicine services are listed below. The AMA’s coding scenarios (PDF) provide real-world examples of how to code for telehealth services.
- For commercial payers, telehealth coverage and payment continues to evolve. These resources are to help track changes in coverage and payment for telemedicine services. Also check with your local state medical association or society for more information.
- COVID-19 telehealth payment policies–Comparison between Medicare FFS and other payors (PDF)
The tables provided on this page give common CPT codes for telemedicine services; other codes may be needed.
- CPT Codes: 99091, 98970, 98971, 98872, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99421, 99422, 99423, 99441, 99442, 99443, 99453, 99454, 99457, 99458, 99473 and 99474
- HCPCS Codes: G2061, G2062, G2063, G2012 and G2010