Telehealth has transformed healthcare delivery, offering convenience, accessibility, and safety, especially during public health emergencies like COVID-19. However, while the benefits of telemedicine are clear, telehealth billing remains a complex and evolving aspect for providers. Navigating this landscape requires a firm grasp of regulations, documentation practices, and payer-specific nuances.
In this blog post, we’ll explore the top telehealth billing tips for providers. These tips will help you avoid common pitfalls and ensure compliance while maximizing reimbursement.
- Understand Telehealth Billing Codes and Modifiers
One crucial component of successful telehealth billing is using the correct Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes. These codes vary depending on the type of telehealth service, platform used, and time spent.
Some commonly used telehealth CPT codes include:
- 99201–99215 – Office or other outpatient visits
- 99421–99423 – Online digital evaluation and management services
- 99441–99443 – Telephone evaluation and management services
You also need to use appropriate modifiers:
- Modifier 95 – Indicates a service was delivered via synchronous telecommunication.
- Modifier GT – Indicates interactive audio and video was used for the service.
- Modifier GQ – For asynchronous services (store-and-forward).
Pro Tip: Review CMS and commercial payer websites regularly for updates, as coverage for telehealth services and associated codes can change frequently.
- Verify Patient Eligibility and Coverage Before Appointments
Not all patients or insurance plans cover telehealth services equally. Even though many payers have expanded telehealth coverage in recent years, there are still limitations based on:
- Type of insurance (Medicare, Medicaid, commercial)
- Patient’s location (urban vs. rural)
- Type of service provided
To avoid denied claims and delayed revenue, verify telehealth eligibility for each patient before the visit. This includes confirming:
- If the payer covers telehealth services
- Any restrictions or limits (e.g., frequency, originating site requirements)
- Patient cost-sharing obligations
- Stay Updated on State and Federal Telehealth Regulations
Telehealth regulations can vary widely from one state to another and change quickly. Key areas to monitor include:
- Licensing requirements: Some states require providers to be licensed in the state where the patient is located.
- Parity laws: These determine whether telehealth services are reimbursed at the same rate as in-person visits.
- Cross-state care allowances: Temporary waivers might exist during emergencies, but could expire or be modified.
Check your state’s telemedicine board and CMS guidelines regularly to stay compliant.
- Use HIPAA-Compliant Technology Platforms
While HIPAA enforcement was temporarily relaxed during the COVID-19 public health emergency, those flexibilities are being phased out. Providers must now use telehealth platforms that comply with HIPAA privacy and security requirements.
A HIPAA-compliant platform ensures:
- End-to-end encryption
- Business Associate Agreements (BAAs) with vendors
- Secure data storage and transmission
Using compliant tools not only protects patient data but also avoids penalties and supports smoother claim processing.
- Document Thoroughly and Accurately
Thorough documentation is essential for successful telehealth billing. Your clinical notes should include:
- Confirmation of patient identity and consent for telehealth
- Location of both provider and patient
- Date and duration of the visit
- Description of technology used (audio-only or audio-visual)
- Clinical findings and decision-making rationale
Proper documentation supports accurate coding and helps defend against audits or denied claims.
- Know the Differences Between Audio-Only and Audio-Visual Visits
Not all telehealth services are created equal. CMS and other payers differentiate between:
- Synchronous audio-video visits: Typically reimbursed at higher rates.
- Audio-only services: Often reimbursed at lower rates, with more limited eligibility.
Use correct codes such as 99441–99443 for audio-only services, and be clear in your documentation about the modality used. Many commercial payers require explicit notation when services are not conducted via video.
- Track Payer Policy Changes Proactively
One of the biggest telehealth billing challenges is the ever-shifting payer landscape. Insurers frequently update:
- Covered services and CPT codes
- Modifiers and place-of-service (POS) requirements
- Reimbursement rates and submission deadlines
Some payers require POS code 02 for telehealth services, while others now require 10 (introduced by CMS for services provided in the patient’s home).
Create a centralized reference document for your billing team and update it monthly or as soon as new guidance is issued.
- Invest in Staff Training and Billing Software
Training your administrative and billing staff is critical. Everyone involved in coding, billing, and claims should understand:
- How to correctly apply telehealth codes and modifiers
- Which documentation is needed for compliance
- How to appeal denied telehealth claims
In addition, using telehealth-ready practice management or revenue cycle software can streamline workflows by:
- Flagging missing or incorrect codes
- Automating eligibility checks
- Managing payer-specific rules
- Audit Telehealth Claims Regularly
A proactive audit process helps you identify billing issues before they result in denials or regulatory penalties. Conduct regular internal reviews to:
- Confirm correct CPT and HCPCS codes were used
- Check modifier and POS code accuracy
- Ensure proper documentation supports the service billed
A quarterly audit cycle is a good starting point. If you’re launching or expanding a telehealth program, consider monthly reviews during the ramp-up phase.
- Prepare for Post-Pandemic Policy Shifts
While many telehealth flexibilities introduced during COVID-19 have been extended, they are not guaranteed to remain indefinitely. CMS and private insurers are still evaluating:
- Which services to make permanent
- Changes to geographic and originating site restrictions
- Adjustments to reimbursement rates
Keep a close eye on CMS updates and pending legislation such as the Telehealth Expansion Act, which may define the future of reimbursement and access.
Mastering Telehealth Billing for Sustainable Practice Success
Telehealth is no longer a temporary solution—it’s a foundational part of modern healthcare delivery. However, to truly reap its benefits, providers must approach telehealth billing with diligence, adaptability, and a commitment to compliance.
From accurate coding and documentation to regulatory awareness and proactive audits, these best practices ensure that your telehealth services are not just clinically effective but also financially sustainable.
By staying informed and investing in robust billing workflows, providers can minimize claim denials, reduce administrative overhead, and continue delivering quality care, no matter where their patients are.
