Telehealth Services

Telehealth Services Overview

Technology Requirements

Distant Site

Eligible Providers

Originating Site

Billing of Telehealth Services

Modifiers

Outpatient Therapy, Diabetes Self Management Training and Medical Nutritional Therapy Services

Teaching Physicians

Consent for Care Management and Virtual Communication Services

Acute Hospital Care at Home

Federally Qualified Health Centers and Rural Health Clinics 

References

Telehealth Services Overview 

Telehealth services are defined as services a physician or practitioner provides via two-way, interactive technology (or telehealth). Telehealth substitutes for an in-person visit and generally involves two-way, interactive technology permitting communication between the practitioner and patient. 

CMS publishes current Medicare requirements for telehealth services within the MLN Booklet MLN901705, Telehealth & Remote Monitoring. The following are a summary of key points from this resource. 

Technology Requirements 

Interactive telecommunications system means multimedia communications equipment including, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner. 

Under current law, patients may continue to receive audio-only telehealth services in their homes through December 31, 2027. Starting January 1, 2028, physicians and practitioners may use two-way, real-time audio-only communication technology for behavioral health services furnished to a patient in their home, provided that the furnishing physician or practitioner is technically capable of using audio-video communication technology and that the beneficiary is not capable of or does not consent to using audio-video communication technology. Audio-only can be used for both new and established patients. Patients who are receiving remote mental health services, furnished by hospital employed staff in their homes may also receive these services via audio-only communication technology.

Distant Site

A distant site is the location from where a physician or practitioner provides telehealth. Through December 31, 2027, all providers who are eligible to bill Medicare for professional services can provide distant site telehealth.

Distant site practitioners can provide telehealth services from their home and in many cases do not need to report their home address. Practitioners who furnish telehealth services from their homes but have a physical practice location are not required to report their home address on their Medicare enrollment application. Instructions regarding how to report addresses for telehealth practitioners, including how to avoid public publishing of home addresses, to Medicare on the provider enrollment application are available within the Telehealth Enrollment Scenarios article. 

Eligible Providers 

The following distant site professionals eligible to bill for telehealth services include:

  • Physicians

  • Nurse practitioners (NPs)

  • Physician assistants (PAs)

  • Clinical nurse-midwives (CNM)

  • Clinical nurse specialists (CNS)

  • Certified registered nurse anesthetists (CRNAs)

  • Clinical psychologists (CPs) 

  • Clinical social workers (CSWs)

  • Registered dietitians (RDs)

  • Nutrition professionals

  • Mental health counselors (MHC)

  • Marriage family therapists (MFT)

The following distant site health care professionals eligible to bill telehealth services through December 31, 2027:

  • Audiologists

  • Occupational therapist (OT)

  • Physical therapist (PT)

  • Speech language pathologist (SLP)

Note:  Distant site professionals may be limited by state scope of practice.

Originating Site

An originating site is the location where a patient is located while receiving physician or practitioner medical services through telehealth. 

Through December 31, 2027, all patients can receive telehealth wherever they are located. They do not need to be at a designated originating site and there are no geographic restrictions.

HCPCS Code Q3014 describes the Medicare telehealth originating site facility fee. The Medicare originating site facility fee amount for CY 2025 is $31.01 and for CY 2026 is $31.85. 

An originating site facility fee is billed when the patient is in a healthcare facility receiving telehealth. Medicare makes payment to the distant site practitioner for the professional services. 

Note: If the patient is within a hospital and receives a hospital outpatient clinic visit (including a mental or behavioral health visit) from a practitioner located in the same physical location, the hospital would bill for the clinic visit (HCPCS code G0463).

Billing and Payment Methodology for Originating Site

Originating Site Payment Methodology Bill Type Revenue Code
Outpatient hospital - includes rural emergency hospitals (REHs) Outside of Outpatient Prospective Payment System (OPPS) 

13X

078X

Inpatient hospital Outside diagnostic related group codes (DRGs) 12X 078X
Critical access hospital (CAH) Separate from cost based (80% or the originating site facility fee) 12X 078X
Federally qualified health center (FQHC) or rural health center (RHC) Separate from Prospective Payment System (PPS) or All-Inclusive Rate (AIR) 77X or 71X 078X
Hospital-based or CAH-based renal dialysis center In addition to ESRD PPS or monthly capitation payment 72X 078X
Skilled nursing facility (SNF) Outside of the SNF PPS (not subject to consolidated billing) 22X or 23X 78X
Community mental health center (CHMC) Not a partial hospitalization service (or used to determine payment for partial hospitalization). Not bundled in per diem. 76X 078X

 

For physician and practitioner offices, the only payable setting for originating site is office, place of service (POS) 11, and the payment amount is the lesser of 80% of the actual charge or 80% of the originating site facility fee, regardless of geographic location.

An originating site can include the home of individual for certain purposes related to ESRD, SUDs and mental health or a mobile stroke unit.

Billing of Telehealth Services

CMS provides the designated List of Telehealth Services. This is the only consolidated listing of approved telehealth services published by CMS.

  • There are two finalized action categories:
    • Maintain - advising the service can be furnished using an interactive, two-way audio-video telecommunications system
    • Addition - new codes added meeting the service can be furnished using an interactive, two-way audio-video telecommunications system 

Modifiers

Telehealth modifiers provide information regarding the modality of delivery by the distant site for telehealth services. Generally, interactive audio and video communications must be used to permit real-time communication between distant site physician or practitioner and patient. Patient must be present and participating in telehealth visit.

Append the following modifiers to telehealth services, when applicable. 

Modifier Description Additional Information
93 Telehealth modifier defined as synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system.

Modifier 93 is used for audio- only communication:

  • Permitted for patients in their home if patient does not have:
  • Technical capacity
  • Availability of real-time audio and visual interactive technology
  • Permitted for patients in their home if patient does not:
  • Consent to the use of 2- way, audio/video technology.

Opioid Treatment Programs (OTPs) report on claims for intake activities, periodic assessments, counseling and therapy provided for audio-only technology:

RHCs and FQHCs can report either modifier 93 or FQ for services provided by audio-only technology.

95 Telehealth modifier defined as synchronous telemedicine service rendered via real-time Interactive audio and video telecommunications system.

Use modifier 95 for:

  • Outpatient therapy services provided via telehealth by qualified physical therapists, occupational therapists, or speech language pathologists employed by hospitals
  • Opioid Treatment Programs (OTPs) report on claims for intake activities, periodic assessments and counseling and therapy provided for using audio-video technology:
FQ The service was furnished using audio-only communication technology. This modifier can only be used by RHCs and FQHCs
G0 (zero) Telehealth services furnished for purposes of diagnosis, evaluation, or treatment of symptoms of an acute stroke. 

Valid for:

  • Telehealth distant site codes billed with place of service (POS) code 02; or
  • CAH method II (revenue codes 096X, 097X, or 098X); or
  • Telehealth originating site facility fee, billed with HCPCS code Q3014.
GQ Telehealth service rendered via asynchronous telecommunications system. Certifying the collection and transmission of the asynchronous medical file at the distant site from a federal telemedicine demonstration conducted in Alaska or Hawaii.
GT Telehealth service via interactive audio and video telecommunication systems. Only allowed on institutional claims billed by CAH method II providers.

Place of Service

Reporting Place of Service Codes (POS) indicates where the patient was located when receiving telehealth services:

  • POS 02 - Telehealth provided other than in patient’s home

    Descriptor: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in the home when receiving health services or health related services through telecommunication technology.

    Services are reimbursed at the facility rate

  • POS 10 - Telehealth provided in patient’s home

    Descriptor: The location where health services and health related services are provided or received through telecommunication technology. Patient is in the home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.

Telehealth services provided in patient homes will be reimbursed at the non-facility PFS rate.

Outpatient Therapy, Diabetes Self Management Training and Medical Nutritional Therapy Services

CMS is continuing to align requirements for payment for services furnished remotely by hospital staff to patients in their homes, including remotely furnished outpatient therapy services, diabetes self management training (DSMT), medical nutritional therapy (MNT) services, with requirements for Medicare telehealth services. Therefore, through December 31, 2027, hospitals can continue to bill for these services. Starting January 1, 2028, hospitals may no longer bill for these services when furnished remotely by hospital staff to patients in their homes.

Teaching Physicians

CMS published Medicare requirements for teaching physicians within the MLN Booklet MLN006347, Guidelines for Teaching Physicians, Interns & Residents. Beginning January 1, 2026, teaching physicians may continue to meet Medicare's presence requirements through a virtual presence in all teaching settings, but only when the service furnished is a Medicare telehealth service. Under this policy, the teaching physician may be present for the key portion of the service using real-time audio/video communication technology, for all residency training locations. 

The policy permanently allows virtual participation when the telehealth service is conducted as a three-way telehealth visit involving the patient, resident, and teaching physician, each located in separate locations. This flexibility applies only to Medicare telehealth services.

Consent for Care Management and Virtual Communication Services

CMS requires patient consent for all services, including non-face-to-face services. Providers may obtain patient consent at the same time the provider initially provides the services. Direct supervision is not required to obtain consent. 

In general, auxiliary personnel under general supervision of the billing practitioner can obtain patient consent for these services. The person getting consent can be an employee, independent contractor, or leased employee of the billing practitioner.

Acute Hospital Care at Home 

The Acute Hospital Care at Home (AHCaH) initiative is a flexibility to allow hospitals to expand their capacity to provide inpatient care in an individual’s home implemented by CMS during the COVID-19 PHE. This expansion relies heavily on telehealth for hospitals to provide inpatient services including routine services, outside the hospital.

This was extended most recently by the H.R.7148 - Consolidated Appropriations Act, 2026. For all hospitals with active AHCAH waivers, all inpatients must be discharged or returned to the hospital on September 30, 2030, in the absence of Congressional action to extend the initiative. CMS will no longer accept waiver requests for participation in the AHCAH initiative after September 1, 2030.

Hospital Billing for Acute Hospital Care at Home

Hospitals bill for services provided consistent with the existing Medicare policies and requirements. Medicare inpatient payments to a hospital will be the same as they would have been if the care were provided in a traditional inpatient setting.

Physician Billing for Acute Hospital Care at Home

Professional claims for telehealth services furnished to patients in an AHCAH stay must be submitted with POS 21 paired with modifier 95, and not POS 10.

Federally Qualified Health Centers and Rural Health Clinics 

Non-behavioral health visits furnished via telecommunication technology under the methodology that has been in place for these services during and after the COVID-19 PHE through December 31, 2026; federally qualified health centers (FQHCs) and rural health clinics (RHCs) can continue to bill for FQHCs and RHCs services furnished using telecommunication technology by reporting HCPCS code G2025.

FQHCs and RHCs bill their Part A MAC using the FQHC and RHC bill type and provider number. 

  • Report revenue code 078X when billing for the originating site facility fee for both FQHCs and RHCs.

Additional information on distant site billing for FQHCs and RHCs can be found in the following resources:

 

References