(Last Updated On: April 13, 2020)

On March 30, 2020, as part of the Centers for Medicare & Medicaid Services (CMS) continued response to the COVID-19 outbreak, CMS released an interim final rule (IFC) that makes a number of changes to further support the delivery of services to patients during this Public Health Emergency. And although this rule was published this week, all the changes made to the rule are retroactive to March 1, 2020. Full details regarding the IFC and the changes therein click here.

Highlights of the various changes that may be particularly significant to you:

  • Telehealth services provided via real-time interactive audio and video should be billed with the place of service (POS) code that would have been used had the service been provided in person. Typically, this would mean that services should be provided using a POS of 11 (instead of 02). CMS has also directed providers to append modifier 95 to all telehealth services billed using POS 11. This change will enable providers to be reimbursed at the same rate as services provided in person.
  • During the current COVID-19 Public Health Emergency, Telehealth E/M levels can be selected based on MDM (Medical Decision Making), or the Time (total time associated with the E/M on the day of the encounter). Likewise, CMS has also removed any requirements regarding documentation of history and/or physical exam in the medical record for Telehealth visits.
  • During the current COVID-19 Public Health Emergency, Telephone E/M services (CPT 99441 – 99443) are now covered by Medicare for new and established patients.
  • Virtual check-in HCPCS codes G2010 and G2012 are now allowed for both new and established patients, while coding descriptions limiting the codes to established patients can be disregarded, during the current COVID-19 Public Health Emergency.

Additional CMS Resources:


In addition to the changes above, CMS has also announced its expansion of the Accelerated and Advance Payment Program for the duration of the current COVID-19 Public Health Emergency. Under this program, providers can request advanced or accelerated payments to help cover costs for a 120-day period following receipt of the advanced payment. Amounts advanced under this program will be recouped from the provider’s Medicare billings at the end of the 120-day period. For additional details on the program, click here.

Please note, that as STI attempts to keep you informed of the latest CMS updates regarding various changes in Telehealth requirements, these requirements, including various billing changes for those services, are changing daily, and we recommend that you check not only with CMS, but also with other individual payers as well, to be sure you are kept abreast of any changes as it may affect your practice and the services you provide.

We want to wish all our healthcare workers well as they care for patients during this public health emergency, and let you know that we are doing our best to support you behind the scenes.

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