A Guide to Telemedicine Reimbursement Regulations

By: on August 18, 2020

Ever since coronavirus hit the U.S. in January, patients, doctors, and legislators have looked to telemedicine as a solution to treat immunocompromised and highly contagious patients while limiting risk.

Since the outbreak, legislators have changed regulations around how telemedicine exams are billed and reimbursed through Medicare and how much access providers have to these remote care tools. While these changes are incredibly valuable in making telemedicine more readily available, the number of changes made in such a short time has left some providers confused about how telemedicine reimbursement works.

If you’re one of those new telemedicine users who has questions, we’ve created this telemedicine reimbursement guide to help provide some clarity.

Telemedicine regulations pre-COVID were limiting

To understand where telemedicine is right now and where it’s going, let’s first review what telemedicine regulations and user guidelines were in place before the pandemic.

Before March 2020, medical providers had to clear many regulatory hurdles in order to use telemedicine, including:

  • Multi-state licensing and credentialing: Providers were required to be licensed in the state they were located as well as the one in which their patients were located, so cross-state care was limited.
  • Billing, coding, and reimbursement: Before 2020, the types of providers who qualified for Medicare reimbursement for telemedicine exams were limited.
  • Privacy compliance: HIPAA regulations imposed strict and severe penalties for violations of patient privacy, and there were not that many compliant telemedicine platforms.

Fortunately, it was easy for everyone to see how valuable telemedicine and remote care tools were going to be for dealing with COVID-19, so lawmakers quickly set about removing these restrictions and creating easier access for doctors and patients alike.

Telemedicine reimbursement changes during COVID

The early changes to telemedicine regulations made in March with the Coronavirus Preparedness and Response Supplemental Appropriations Act and the CARES Act removed a lot of restrictions around accessing telemedicine, including:

  • Reimbursements: It expands the types of providers who can be reimbursed through Medicare for patient visits conducted via telemedicine and also allows remote exams to be reimbursed at the same rate as in-person visits.
  • Waiving state licensing barriers: This allows healthcare providers to treat Medicare patients via telemedicine regardless of their location. The same waivers are available upon request for Medicaid patients.
  • Exercising “enforcement discretion”: This is regarding HIPAA penalties for failure to comply with regulatory requirements in the course of “good faith provision of telehealth” services. In other words, providers and patients were allowed to use non-HIPAA certified telemedicine platforms to conduct patient visits.

At the time that these pieces of legislation were passed, it was made clear that they were intended to be temporary measures that would only last the duration of the COVID-19 pandemic. However, as we approach a year of coronavirus cases in the U.S., it looks like telemedicine is still the best tool we have to fight the pandemic.

At the end of April 2020, the Centers for Medicare and Medicaid Services (CMS) announced additional directives expanding on the regulatory changes made the previous month. These included:

  • Waiving remaining limitations on specialist providers eligible for reimbursement of telemedicine appointments through Medicare to include physical therapists, occupational therapists, and speech language pathologists.
  • Allowing hospitals to bill for remote outpatient services provided by hospital-based healthcare providers.
  • Broadening the list of audio-only phone services eligible for Medicare reimbursement to include a variety of services, including behavioral health and patient education. CMS also increased reimbursements for these services to equal similar office or outpatient services.
  • Waiving the video requirement for specific evaluation and healthcare management services, which allows providers to be reimbursed for treatment delivered by phone.

All of these changes paint a great picture for providers and patients in broad strokes, but let’s take a look at the actual steps of coding and submitting claims for reimbursement.

Coding and billing for telehealth during COVID

The silver lining of these major changes is that there are plenty of resources and helpful tools available to make finding updated codes easier and ensure claims are as accurate as possible. Here are just a few available from the CMS for you to check out:

Using these and other ICD resources, coding for telemedicine reimbursement should be fairly straightforward.

Remember to use CPT or HCPCS codes when submitting telehealth service claims, and add a telehealth GQ modifier to claims involving services provided through asynchronous telemedicine tools.

You can download a full list of telehealth services payable under the Medicare Physician Fee Schedule, including temporary additions, here.

Anticipating the future of telemedicine

Predicting the future is never easy, but in the middle of an unprecedented global pandemic it becomes even more difficult. That said, we can still make educated guesses about how we’ll continue to navigate this virus, and telemedicine seems like it will continue to play a big part.

We’ve known for a while now that patients appreciate the option to conduct visits remotely, and patient demand for telemedicine services has grown significantly over the years.

We also know, according to a recent survey* of over 500 U.S. patients, that a majority will outright refuse in-person appointments with providers who aren’t following local safety regulations to prevent the spread of the virus. Over half of those patients believe doctors should be relying on telemedicine as much as possible to see patients during the pandemic.

With this in mind and seeing how legislators have made every move to expand access to telemedicine this year, investing in a robust telemedicine platform is a wise move for the future of your practice.


We surveyed over 500 patients in the United States to gather the data reported here. We used screening questions to narrow the number of respondents down to 564 with relevant histories and experiences. We worded the questions to ensure that each respondent fully understood their meaning and the topic at hand.

The information contained in this article has been obtained from sources believed to be reliable.

For more information, see our methodologies page. If you would like to obtain the charts in this report, contact lisa.hedges@gartner.com.

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