enacted.” New reimbursement policies and codes, which were
effective January 2019, were enacted for other types of services
furnished remotely using telecommunications technologies that
CMS does not consider Medicare telehealth services and are
therefore not subject to the restrictions under section 1834(m).
The following services are deemed reimbursable under the
2019 Medicare Physician Fee Schedule (MPFS) Final Rule:
Brief Communication Technology Based Services
New HCPCS Code: G2012
When a physician or other qualified healthcare professional has a brief non–face-to-face check-in with a patient
via communication technology to assess whether the patient’s condition necessitates an office visit.
Service occurs real-time and does not involve transmission of a recorded image.
CMS requires verbal patient consent be documented in
the medical record.
Remote Evaluation of Pre-Recorded Patient Information
New HCPCS Code: G2010
Remote professional evaluation of patient-transmitted information conducted via pre-recorded store-and-forward
video or image technology.
Service involves provider’s evaluation of a patient-gener-ated still or video image and the communication back to
CMS requires verbal or written patient consent.
Interprofessional Internet Consultation
Revised CPT Codes: 99446-99449
New CPT Codes: 99451-99452
Service involves consultations between professionals via
communications technologies, such as telephone or internet.
CMS requires verbal patient consent.
Beginning in 2019, several changes made under the Bipartisan Act of 2018 allowed CMS to change the originating site geographic conditions found in section 1834(m) for treatment of
end-stage renal disease and acute stroke patients. They include
the inclusion of renal dialysis facilities and an individual’s home
as permissible originating telehealth services sites for treatment
of end-stage renal disease as well as the inclusion of an individual’s home as an originating site for patients with substance
use disorder or a co-occurring mental health disorder. Under
the new rules, treatment of strokes through telehealth is now
permissible in any hospital, critical access hospital, or mobile
Despite CMS’ initiatives toward increasing the utilization of
innovative technologies and telehealth services by Medicare
beneficiaries, individual states still vary in their coverage under
Medicaid programs, private insurance, and laws pertaining to
telehealth. A study in May 2019 by the Center for Connected
Health Policy found there are varying degrees of regulation for
eligible originating sites.
For further state-specific information regarding telehealth law,
visit the Center for Health Policy’s online tool at www.cchpca.
1. Centers for Medicare and Medicaid Services (CMS). “CMS
Proposes Historic Changes to Modernize Medicare and
Restore the Doctor-Patient Relationship.” July 12, 2018.
Social Security Administration. “Compilation of the Social
Security Laws. Special Payment Rules for Particular Items
and Services.” https://www.ssa.gov/OP_Home/ssact/
Centers for Medicare and Medicaid Services. “Medicare
Program Revisions to Payment Policies Under the
Physician Fee Schedule and Other Revisions to Part B for
C Y 2019.” Federal Register. November 23, 2018. https://www.
CMS. “CMS Proposes to Modernize Medicare Advantage,
Expand Telehealth Access for Patients.” October, 26,
CMS. “CMS finalizes policies to bring innovative telehealth
benefit to Medicare Advantage.” April 5, 2019. https://www.
CMS. “CMS Finalizes Changes to Advance Innovation, Restore
Focus on Patients.” November 1, 2018. https://www.cms.
Center for Connected Health Policy. “State Telehealth Laws
and Reimbursement Policies Report.” Spring 2019. https://
Center for Connected Health Policy. “CMS Finalized Telehealth
Changes to Physician Fee Schedule CY 2019.” https://
Center for Connected Health Policy. “Big Changes in 2019 for
Medicare Telehealth Policy.” November 6, 2018.ht tps://
Sandra Hernandez ( firstname.lastname@example.org) is director of coding at OrthoAtlanta.