Last Updated: July 31, 2023

A health carrier may not exclude an ​otherwise covered health care ​service from coverage solely because ​the service is provided through ​telehealth rather than to face-to-face ​consultation or contact between a ​health care provider and a patient. A ​health carrier or health benefit plan ​may limit coverage for health care ​services that are provided through ​telehealth to health care providers ​that are in a network approved by ​the plan or the health carrier.

MO Revised Statutes Section ​376.1900

• Asynchronous (Store and Forward) technology: Also called “store and forward” technology, asynchronous technology means the transmission of a patient's medical information to a physician or practitioner located at a distant site to be reviewed at a later time. The physician or practitioner at the distant site reviews the case without the patient being present. Store and forward substitutes for an interactive encounter with the patient present; the patient is not present in real-time.
  

• Audio-only visits: Use of telephone or other audio technologies for synchronous, two-way, real-time services without video.
  

• Communication technology-based services (CTBS): Services furnished remotely using communications technology, but which are not considered Medicare telehealth services. Because they do not fall under the telehealth benefit, the limitations and restrictions applicable to telehealth under Medicare’s rules do not apply. Services Medicare covers as CTBS include phone assessments, remote evaluation of videos/images, virtual check-ins, and e-visits.
  

• Distant site: The site at which the healthcare professional delivering the service is located at the time the service is provided via a telecommunications system.

• E-visits: A non- face to face patient-initiated communication between a patient and their provider, generally using asynchronous technology such as an online patient portal.

• Eligible distant site provider: A specified list of health care professionals or entities which can provide and be paid for telehealth services under Medicare: physicians; nurse practitioners; physician assistants; nurse midwives; clinical nurse specialists; certified registered nurse anesthetists, clinical psychologists and clinical social workers; and registered dietitians or nutrition professionals. Note: Flexibilities during the COVID-19 PHE allowed any professional eligible to bill Medicare as an eligible distant site professional including critical access hospitals. When the PHE ended May 12, 2023, CAHs and any professional not permitted to act as an eligible distant site provider prior to the PHE were no longer eligible to be paid for telehealth by Medicare except physical, occupational and speech therapy professionals who will remain eligible distant site providers until December 31, 2024.
  

• Interactive telecommunication system: Multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site provider.

• Originating site: The location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs.
  

• Remote patient monitoring: Non- face to face use of digital technologies to collect health data from patients in one location and transmit that information securely to providers in a different location. Remote physiologic monitoring refers to the electronic transmission of objective, physiologic parameters such as blood pressure, pulse oximetry, weight, or temperature. Remote therapeutic monitoring involves monitoring subjective data related to signs, symptoms, and responses to treatment.
  

• Telehealth service: The use of telecommunications and information technology to provide access to health assessment, diagnosis, intervention, consultation, supervision and information across distance. Telehealth is sometimes referred to as telemedicine. The word 'telehealth' is a term of art under the Medicare program. It is a specific service benefit with a specific set of rules prerequisite to coverage and payment.
  

• Virtual check-In: a brief (5-10 minute) check-in with a provider via telephone or other telecommunications device to decide whether an office visit or other service is needed.
  

Medicare does not formally require specific consent before a telehealth services. Missouri state law does require that: Telehealth providers obtain the patient’s or the patient’s guardian’s consent before telehealth services are initiated and shall document the patient’s or the patient’s guardian’s consent in the patient’s file or chart. See 20 CSR 2150-2.240; 20 CSR 2150-5.100.

Missouri does not necessarily require written consent signed by the patient for telehealth services. As with the federal Department of Health and Human Services, obtaining consent from patients before a telehealth session can include signed paperwork completed before the appointment or verbal consent at the beginning of a telehealth session. Verbal consent is then recorded by the clinician into the patient's health record.

True telehealth, as Medicare defines the benefit, generally requires an interactive telecommunication system must be used for telehealth, permitting real-time communication between the distant site provider and the Medicare beneficiary.

Virtual check-ins or brief communication technology-based services are a brief, non- face to face check-in with an established patient via ​communication technology to assess whether or not an office visit or other service is necessary. This could take place via live video or ​telephone call. This service is only available to practitioners who furnish E/M services, and could take place via live video or telephone call.

Geographic Requirements for Medicare telehealth services are waived through December 31, 2024. Medicare historically has treated telehealth almost exclusively as a tool for rural areas, and narrowly restricted the geographic areas eligible for use of telehealth. Under the Medicare policy, the beneficiary must be located in:

• a county outside of a Metropolitan Statistical Area (MSA) (as defined by the U.S. Census Bureau);
  

• a Rural Health Professional Shortage Area (HPSA) (as defined by Health Resources and Services Administration); or
  

• from an entity that participates in a Federal telemedicine demonstration project that had been approved by (or receives funding from) the Secretary of Health and Human Services as of December 31, 2000.

The following describe permanent exceptions to the geographic restrictions of Medicare telehealth

Geographic limitations do no apply to services furnished for the purpose of diagnosis, evaluation, or treatment of symptoms of an acute stroke. For the treatment of acute stroke, a mobile stroke unit along with any currently eligible originating site, is eligible for telehealth reimbursement. However, originating sites that would not otherwise qualify for telehealth reimbursement (under Medicare’s geographic and originating site requirements) would not be eligible for the facility fee.

An originating site is the location where the patient is at the time the telehealth encounter occurs. Medicare places geographic and site specific limitation on this. For more information on Geographic Requirements click here. Ordinarily, eligible originating sites include:

• Offices of a Physician or Practitioner
  
• Hospitals
  
• Critical Access Hospitals
  
• Community Mental Health Centers
  
• Skilled Nursing Facilities
  
• Rural Health Clinics
  
• Federally Qualified Health Centers
  
• Hospital-Based or Critical Access Hospital-Based Renal Dialysis Centers (including satellites)
  
• Renal Dialysis Facilities
  
• Homes of beneficiaries with End-Stage Renal Disease getting home dialysis
  
• Mobile Stroke Units
  
• Rural Emergency Hospitals

• POS 02: Telehealth provided other than in patient's home. Patient is not located in their home when receiving health services or health related services through telecommunication technology. When used, POS 02 causes a service to be paid at a lower, facility-based rate of payment.
  

• POS 10: Telehealth provided in patient's home. Patient is located in their 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. As of January 1, 2024, CMS announced POS 10 will be reimbursed at the higher, non-facility rate of payment.
  

A distant site under Medicare means a site where a provider of ​telehealth is located at the time the service is provided via ​telecommunications technology.

FQHCs and RHCs are temporarily added to the eligible list of who ​may serve as distant site providers through December 31, 2024. ​See Sect 4113 of the Consolidated Appropriations Act, 2023 here. ​After December 31, 2024, FQHCs will still be able to serve as a ​distant site provider for certain behavioral/mental telehealth services ​only.

FQHCs bill using HCPCS code G2025 to bill as distant site telehealth ​provider and will not receive payment like they do for their usual PPS ​visits.

To ease the burden for providers to be licensed in multiple states, many states have enacted legislation to create interstate compacts. This allows providers to obtain a license in another state a bit easier. Missouri is part of several licensure compacts. Click any of the following compacts’ names to learn more.

• Psychology Interjurisdictional Compact
  
• Physical Therapy Compact
  
• Nurses Licensure Compact
  
• The Interstate Commission for EMS Personnel Practice
  
• Occupational Therapy Licensure Compact
  
• Audiology and Speech-language Pathology Interstate Compact
  

To qualify as a FQHC mental health visit, the encounter must include a qualified mental health service, ​such as a psychiatric diagnostic evaluation or psychotherapy.

Effective January 1, 2022, a mental health visit is a face-to-face encounter or an ​encounter furnished using interactive, real-time, audio and video ​telecommunications technology or audio-only interactions in cases where the ​patient is not capable of, or does not consent to, the use of video technology for ​the purposes of diagnosis, evaluation or treatment of a mental health disorder.

In person (without the use of telecommunications) visits are required for mental ​health telehealth services and mental health visits furnished by FQHCs begin on ​January 1, 2025:

• within 6 months prior to the furnishing of the mental health service furnished ​via telecommunications
  
• at least every 12 months while the beneficiary is receiving services furnished via ​telecommunications technology for diagnosis, evaluation, or treatment of ​mental health disorders

Section 4113 of the Consolidated Appropriations Act, 2023 delayed the in-person ​visit requirements under Medicare for Mental health visits that RHC's and FQHC's ​provide via telecommunications technology until January 1, 2025.

An annual in-person visit is not required if:

• risks and burdens of an in-person visit may outweigh the benefit.
• an in-person visit is likely to cause disruption in service delivery or has the ​potential to worsen the patient's condition
  
• the patient getting services is in partial or full remission and only needs ​maintenance level care
• in the clinician's professional judgment, the patient is clinically stable and an in-​person visit has the risk of worsening the patient's condition, creating undue ​hardship on self or family
• the patient is at risk of withdrawing from care

Although FQHC services are not subject to the Medicare deductible, the deductible must be applied when an FQHC bills for the telehealth originating site facility fee because this is not considered an FQHC service.

Geographic limits are waived for behavioral health services. Patients can be located in their home at the time an FQHC telehealth service is rendered.

Modifier -95 is no longer used per MPFS 2024 ​effective January 1, 2024 for most services. Instead, ​POS 10 and 02 are used. But modifier 95 should be ​used for telehealth services, when the clinician is in ​the hospital and the patient is in the home, as well as ​for outpatient therapy services furnished via ​telehealth by PT, OT, or SLP

• Federally Qualified Health Centers (FQHC) Center - The Centers for Medicare & Medicaid Services
• Billing for telehealth - The U.S. Department of Health and Human Services
• Billing Medicare as a safety-net provider - The U.S. Department of Health and Human Services
  

G0469 – FQHC visit, mental health, new patient A medically-necessary, face-to-​face (one-on-one) mental health encounter between a new patient and a qualified ​FQHC practitioner during which time one or more FQHC services are rendered and ​includes a typical bundle of services that would be furnished per diem to a ​Medicare beneficiary receiving a mental health visit.

G0470 – FQHC visit, mental health, established patient A medically-necessary, ​face-to-face (one-on-one) mental health encounter between an established patient ​and a qualified FQHC practitioner during which time one or more FQHC services ​are rendered and includes a typical bundle of services that would be furnished per ​diem to a Medicare beneficiary receiving a mental health visit. An established ​patient is one who has received any professional medical or mental health services ​from any practitioner within the FQHC organization or from any sites within the ​FQHC organization within three years prior to the date of service.

If an established patient is receiving both a medical and mental health visit on the same day, the FQHC can bill for 2 visits and should use G0467 to bill for the medical visit and G0470 to bill for the mental health visit

• Medication management, or a psychotherapy “add on” service, is not a separately billable service in an FQHC and is included in the payment of an FQHC medical visit
• FQHCs may bill the Telehealth originating site facility fee on a FQHC claim under revenue code 0780 and HCPCS code Q3014
• Telehealth services are the only services billed on FQHC claims that are subject to the Part B deductible
  

Assign ICD-10-CM code(s) as appropriate based on the Official Guidelines for Coding and Reporting.

Remote patient monitoring is a way for a patient's health to be ​monitored without having to come into the office for multiple check ​ups. Some remote monitoring devices for maternity care may ​include:

• Blood pressure monitors
  
• Blood glucose testing
  
• At home fetal monitors
  

Although remote monitoring is not a face to face service, it does not ​fall under the Medicare telehealth benefit. Effective January 1, 2024, ​FQHCs and RHCs can begin billing for remote monitoring services ​separate from their PPS rate. To be paid by Medicare for remote ​monitoring there must be:

• an established patient-physician relationship
  
• documented consent
  

FQHCs report G0511 for remote patient monitoring that would otherwise meet criteria for RPM or RTM under CPT coding rules.

2024 Medicare payment for G0511 is $72.98

• Federally Qualified Health Centers (FQHC) Center - The Centers for Medicare & Medicaid Services
• Billing for telehealth - The U.S. Department of Health and Human Services
• Billing Medicare as a safety-net provider - The U.S. Department of Health and Human Services
  

Remote patient monitoring is a way for a patient's health to be ​monitored without having to come into the office for multiple check ​ups. Some remote monitoring devices for maternity care may ​include:

• Blood pressure monitors
  
• Blood glucose testing
  
• At home fetal monitors
  

Although remote monitoring is not a face to face service, it does not ​fall under the Medicare telehealth benefit. Effective January 1, 2024, ​FQHCs and RHCs can begin billing for remote monitoring services ​separate from their PPS rate. To be paid by Medicare for remote ​monitoring there must be:

• an established patient-physician relationship
  
• documented consent
  

FQHCs report G0511 for remote patient monitoring that would otherwise meet criteria for RPM or RTM under CPT coding rules.

2024 Medicare payment for G0511 is $72.98

• Federally Qualified Health Centers (FQHC) Center - ​The Centers for Medicare & Medicaid Services
• Billing for telehealth - The U.S. Department of Health ​and Human Services
• Billing Medicare as a safety-net provider - The U.S. ​Department of Health and Human Services
  

Remote patient monitoring is a way for a patient's health to be monitored without having to come into the office for multiple check ups. Some remote monitoring devices for maternity care may include:

• Blood pressure monitors
  
• Blood glucose testing
  
• At home fetal monitors
  

Note that these services are a quasi-telehealth service. meaning Medicare telehealth requirements (e.g. geographic location) do not apply. However, Medicare may have other payment policies in place for the use of remote physiologic monitoring. These may include:

• An established patient-physician relationship
  
• Consent to receive remote physiologic monitoring services at the time services are furnished
  
• Physician and non-physician practitioners who are eligible to furnish evaluation and management services may bill for remote physiologic monitoring services
  

Modifier -95 is no longer used per MPFS 2024 effective ​January 1, 2024 for most services. Instead, POS 10 and 02 ​are used. But modifier 95 should be used for telehealth ​services, when the clinician is in the hospital and the ​patient is in the home, as well as for outpatient therapy ​services furnished via telehealth by PT, OT, or SLP

• Federally Qualified Health Centers (FQHC) Center - The Centers for Medicare & Medicaid Services
• Billing for telehealth - The U.S. Department of Health and Human Services
• Billing Medicare as a safety-net provider - The U.S. Department of Health and Human Services
  

Tip: Services provided virtually while the provider and patient are in the same location - for instance, over a tablet from different rooms within a ​hospital - are not billed as telehealth.

General Billing Tips

There are more than 100 telehealth services covered under Medicare. However some codes are only covered temporarily. Using an incorrect code may delay reimbursement. Stay up to date on the latest Medicare billing codes. Make post-visit documentation as thorough as possible. Take note of whether the patient gave verbal or written consent to conduct a virtual appointment. Only bill for time the provider spent with the patient rather than the time the patient spent with clinical staff. Use telephone codes for audio-only appointments and office codes for audio-visual visits.

Post PHE Billing Policy - FAQs

There have been may temporary waivers during the pandemic for telehealth services. Some waivers will be permanent but many will no longer be in place after December 31, 2024. For more information please click here.

The following HCPCS codes have been revised to reflect updates

in the Consolidated Appropriations Act (CAA), 2023:

• Asynchronous (Store and Forward) technologies: the collection of a patient's relevant health information and the subsequent transmission of that information from an originating site to a health care provider at a distant site without the patient being present.
  

• Distant site: a site at which a health care provider is located while providing health care services by means of telemedicine.

• Eligible providers: any licensed health care provider shall be authorized to provide telehealth services if the services provided are within the scope of practice for which the health care provider is licensed and are provided with the same standard of care as services provided in person.
  

• Home telemonitoring services: a health care service that requires scheduled remote monitoring of data related to a participant's health and transmission of data to a health call center accredited by the Utilization Review Accreditation Commission (URAC)
  

• Originating site: a site at which the patient is located at the time health care services are provided by means of telemedicine. For the purposes of asynchronous or store and forward transfer, originating site shall also mean the location at which the health care provider transfers information to the distant site.
  

• Telehealth or telemedicine: the delivery of health care services by means of information and communication technologies which facilitate the assessment, diagnosis, consultation, treatment, education, care management, and self-management of a patient's health care while such patient is at the originating site and health care provider is at the distant site. Telehealth or telemedicine shall also include the use of asynchronous store and forward technology.
  

Missouri state law requires that: Telehealth providers obtain the patient’s or the patient’s guardian’s consent before telehealth services are initiated and shall document the patient’s or the patient’s guardian’s consent in the patient’s file or chart. See 20 CSR 2150-2.240; 20 CSR 2150-5.100.

Missouri does not necessarily require written consent signed by the patient for telehealth services. Obtaining consent from patients before a telehealth session can include signed paperwork completed before the appointment or verbal consent at the beginning of a telehealth session. Verbal consent is then recorded by the clinician into the patient's health record.

• Informed Consent National Policy Center - Center for Connected health Policy
• Current State Laws & Reimbursement Policies National Policy Center - Center for Connected Health Policy
• How to Obtain Informed Consent for Telehealth Agency for Healthcare Research and Quality
• Easy-to-Understand Telehealth Consent Form Agency for Healthcare Research and Quality
• Obtaining Informed Consent U.S. Department of Health and Human Services
• Obtaining Informed Consent for Telebehavioral Health U.S. Department of Health and Human Services
  

The U.S. Department of Health and Human Services gives additional tips for telebehavioral health. Aside from the best s listed above consider doing the following:

The state of Missouri does not place geographic limitations on telehealth services like Medicare does. Payment for services rendered via telehealth do not depend on any minimum distance requirements between the originating and distant site. Additionally, advanced practice registered nurses providing nursing services under a collaborative practice agreement may provide such services outside normal geographic proximity requirements under RSMo 334.104 if the collaborating physician and advanced practice registered nurse utilize telehealth.

An originating site is the location where the patient is physically located at the time the telehealth encounter occurs. Originating sites allowed by Missouri Medicaid include, but are not necessarily limited to health care provider facilities, participant's homes, and schools. For the purposes of asynchronous store-and-forward transfer, the originating site shall also mean the location from which the referring provider transfers information to the distant site. Originating sites are only eligible to receive a facility fee for the Telemedicine service. The originating site fee and distant site services can be billed by the same provider for the same date of service as long as the distant site is not located in the originating site facility.

When a participant is located in a residential or inpatient place of service (Place of services otherwise described by codes 14, 21, 33, 51, 55, 56, or 61), distant site telehealth providers delivering behavioral health services must report the GT modifier and with the place of service where the participant is physically located. In these instances, providers must not bill with place of service 02.

A distant site under Medicaid means a site where the health care provider is physically ​located at the time the service is provided via telecommunications. Reimbursement to ​providers at the distant site is equal to the current fee schedule amount for the service ​provided. Missouri Medicaid does not have a separate fee schedule for telehealth. Use the ​appropriate CPT code for the service along with the appropriate place of service code. The ​originating site fee and distant site services can be billed by the same provider for the same ​date of service as long as the distant site is not located in the originating site facility.

Providers delivering behavioral health services via telemedicine, for participants located in a ​residential or inpatient place of service (POS codes 14, 21, 33, 51, 55, 56 or 61), must bill with ​the GT modifier and with the place of service where the participant is physically located.

Hospitals may bill a facility fee for distant site services provided in their facilities. The distant ​site service must be reported on the UB04 claim form with the procedure code and GT ​modifier. The physician providing the service will bill for their distant site services on the ​medical claim form.

Distant site services provided on school grounds should be billed with place of service 03 ​and a GT modifier. The provider must get consent from the parent or guardian to provide ​telemedicine services. The parent or guardian may authorize services via telemedicine for a ​whole school year.