This post briefly discusses an article on the Medicare telehealth waivers published by CMS in March and April of 2020.

The article provides an overview of Medicare eligible telehealth services during the current pandemic.  It provides a list of the 238 services now eligible for reimbursement, up from less than 100 prior to March 1, 2020. Many of the restrictions limiting how these services may be provided, including the originating (patient) location, have been changed.

Because of these changes many of the barriers to providing telehealth services to Medicare beneficiaries have been removed.  Many commercial payers are offering similar incentives for the use of telehealth.

Significant changes were made to the Medicare documentation requirements for office visit evaluation and management codes 99201-99215.  The history and physical examination components of the encounter document will no longer be used to determine level of service. It will be based solely on the amount of time spent caring for the patient during the calendar day or the level of complexity of medical decision-making.  These changes were slated for January 1, 2021, but were put in place 10 months ahead of schedule, on March 1, 2020 in response to the public health emergency.

Medicare recently approved the use of telephone (audio-only) codes and on April 29, 2020 CMS made reimbursement for these services (CPT codes 99441-99443) equivalent to office visit E/M codes 99212-99214. Additional information is provided in the article.

A large number of services have now been approved for telehealth and a significant number of these have been reduced to requiring 2-way audio communication only. These codes affect many of the codes used by mental and behavioral health providers.

The article also discusses e-visit and virtual check-in services.  The reimbursement for e-visits is determined by the amount of provider time spent communicating with patient via electronic communications and other methods over a seven-day period. There are 3 codes that can be billed by physicians and other qualified healthcare professionals: 99421, 99422, and 99423. Reimbursement for code 99423 is approximately $51. It requires 21 more minutes of provider time and this time must be spent in written or verbal communication with patient. Other requirements apply as detailed in the article.

The article was originally published by the Journal of AHIMA on April 29th.  It was updated on May 7, 2020 in response to the additional waivers released by Medicare on April 29, 2020.

Reprints are available by request.  Please email